Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com Services LLC

Filing 85

ORDER granting 82 Letter Motion to Seal. Application GRANTED. The redacted information in the Amended Complaint is the same information that the Court previously allowed be filed in redacted form, with unredacted versions filed under seal, in the Order at Dkt. 81. The Clerk of Court is respectfully directed to maintain Dkt. 83 under seal and to close the motion at Dkt. 82. (Signed by Judge Lorna G. Schofield on 2/6/24) (yv)

KASOWITZ BENSON TORRES

LLP
ATLANTA
H OUSTON
LOS ANGELES
MIAMI
N EWARK
SAN F RANCISCO
SILICON VALLEY
W ASHINGTON DC

1633 BROADWAY
NEW YORK, NEW YORK 10019
MARC E. KASOWITZ
DIRECT DIAL: 212-506-1710
DIRECT FAX: [phone]
MKASOWITZ @ KASOWITZ .COM

[phone]
FAX: [phone]

February 5, 2024
VIA ECF
Hon. Lorna G. Schofield
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re:

Binh Thanh Import Export Prod. & Trade Joint Stock Co. v. Amazon.com Servs. LLC,
No. 1:23-cv-00292-LGS – Letter Motion to File Under Seal

Your Honor:
On behalf of plaintiff Binh Thanh Import Export Production & Trade Joint Stock Co.
(“Gilimex”) in the above action, and pursuant to the Court’s February 2, 2024 Order (Dkt. 80)
granting Gilimex leave to amend its complaint, and February 5, 2024 Order (Dkt. 81) approving
defendant Amazon.com Services LLC’s (“Amazon”) proposed redactions and ordering the sealing
of the proposed First Amended Complaint (Dkts. 57, 58), we respectfully move the Court to treat
as sealed the unredacted version of Gilimex’s First Amended Complaint. Gilimex has also filed a
redacted version of the First Amended Complaint, consistent with redactions proposed by Amazon
in its November 13, 2023 letter to the Court (Dkt. 61).
The First Amended Complaint references certain information provided by Amazon during
discovery that has been designated by Amazon as CONFIDENTIAL or CONFIDENTIALATTORNEY’S EYES ONLY pursuant to the February 21, 2023 Stipulation and Confidentiality
Order (Dkt. 25). Given the confidentiality designations and the Court’s February 5, 2024 order,
Gilimex has filed the unredacted First Amended Complaint under seal.
Respectfully,
/s/ Marc E. Kasowitz

cc:

All Counsel of Record

KASOWITZ BENSON TORRES

LLP

Hon. Lorna G. Schofield
February 5, 2024
Page 2 of 2
Appendix
Pursuant to Your Honor’s Individual Rule I.D.3, included below is a list of all parties and
attorneys of record who should have access to the sealed documents:
KASOWITZ BENSON TORRES LLP
Marc E. Kasowitz
Edward E. Filusch
Victor J. Brienza
1633 Broadway
New York, New York 10019
Attorneys for Plaintiff Binh Thanh Import
Export Production & Trade Joint Stock Co.

PERKINS COIE LLP
Alan B. Howard
Adam R. Mandelsberg
Margaret W. Meyers
Evelyn Y. Pang
1155 Avenue of the Americas
22nd Floor
New York, New York 10036
Attorneys for Defendant Amazon.com
Services LLC

Application GRANTED. The redacted information in the Amended Complaint is the same information
that the Court previously allowed be filed in redacted form, with unredacted versions filed under
seal, in the Order at Dkt. 81.
The Clerk of Court is respectfully directed to maintain Dkt. 83 under seal and to close the motion at
Dkt. 82.
Dated: February 6, 2024
New York, New York