Innovatus Capital Partners, LLC v. Neuman et al

Filing 324

ORDER granting 312 Letter Motion to Seal. After inspection of the exhibits, this application is granted and the four exhibits may be sealed on the above-mentioned understanding. (Signed by Judge Louis L. Stanton on 3/29/2022) (rro)

Case 1:18-cv-04252-LLS Document 322 Filed 03/24/22 Page 1 of 1
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COVINGTON
BEIJING

BRUSSELS

LOS ANGELES

SHANGHAI

DUBAI

NEW YORK

JOHANNESBURG
SAN FRANCISCO

SILICON VALLEY

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Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-495
T + 1 202 662 6000

LONDON
SEOUL

WASHINGTON

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MV Realty therefore requests that the Court grant Innovatus' motion to seal with respect
to Exhibits 5, 6, 7, and 12.

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Sincerely,

s/ Jason C. Raofield
Jason C. Raofield

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Of the twelve exhibits attached to Innovatus' motion, MV Realty seeks to seal only four:
Exhibits 5, 6, 7, and 12. These exhibits are confidential draft presentation materials relating to
MV Realty's business, which include detailed information regarding its "business thought
processes" and the "roadmap" or approach it has used in its RTL business. (Dkt. 201.) MV Realty
would be harmed by the disclosure of these materials to competitors, including Innovatus, which
has been attempting to pursue an RTL business of its own. These materials are squarely within
the type of materials that the Court has allowed the parties to seal on the basis of the "muchreduced level of secrecy required to be shown to justify sealing materials" at this stage of the
litigation. (Id.) MV Realty is aware of the Court's order indicating that materials which are sealed
at this stage may nonetheless "need to be revealed at trial." (Dkt, 235.)

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We write in response to Innovatus' March 17, 2022 letter motion (Dkt, 312) seeking leave
to file under seal twelve exhibits to Innovatus' March 17 motion to stay proceedings pending
appeal (Dkt. 313) on the basis of confidentiality designations made by MV Realty when producing
documents pursuant to the Protective Order. 1

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Dear Judge Stanton:

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All citations to "Dkt." refer to the docket in Innovatus Capital Partners, LLC v. Neuman, et al.,
No. 1-18-cv-04252-LLS (S.D.N.Y.). Innovatus filed an identical letter in MV Realty PBC, LLC v.
Innovatus Capital Partners, LLC, No. 1-18-cv-07142-LLS (S.D.N.Y.). See Dkt. 268, 269.
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Re: MV Realty, PBC, LLC, v. Innovatus Capital Partners, LLC (1:18-cv07142); Innovatus v. Neuman et al. (1:18-cv-04252)

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The Honorable Louis L Stanton
United States District Court for the Southern District of New York
500 Pearl Street, Courtroom 21-C
New York, New York 10007

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March 24, 2022

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