In re: Subpeonas to Leeds Equity Partners and Jacques Galante

Filing 21

ORDER granting 20 Letter Motion to Seal. GRANTED ECF 15 SHALL BE SEALED PROVISIONALLY UNTIL THE RESOLUTION OF PENDING MOTION AT ECF 1 & 12. SO ORDERED. (Signed by Judge Mary Kay Vyskocil on 3/11/2025) (jjc)

March 11, 2025
VIA CM/ECF

Honorable Mary K. Vyskocil
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312

Re:

Norton Rose Fulbright US LLP
1301 Avenue of the Americas
New York, New York 10019-6022
United States of America
Direct line [phone]
[e-mail]
Tel [phone]
Fax [phone]

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 3/11/2025

Emergency Request to Seal ECF No. 15, In re Subpoenas to Leeds Equity Partners and
Jacques Galante Misc. No. 1:25-mc-00079 (S.D.N.Y.), Related to UWorld, LLC fka
USMLEWorld, LLC v. USMLE Galaxy, LLC DBA Archer Review and Tart Labs, No. 3:23cv-00447 (N.D. Tex.)

Dear Judge Vyskocil:
Pursuant to Rule 7.1(e) of the Local Rules of the United States District Courts for the Southern
and Eastern Districts of New York, the Southern District of New York’s Sealed Records Filing
Instructions, and Rule 9(B) of the Individual Rules of Practice in Civil Cases, UWorld, LLC, f/k/a
USMLEWorld, LLC (“UWorld”) respectfully submits this letter requesting the emergency sealing
of ECF No. 15. UWorld submits in its place a public letter regarding the sealing of ECF No. 17,
17-1, included as Exhibit A. Alternatively, UWorld submits a version of ECF No. 15 redacting the
confidential information.
“Although the right of public access to court records is firmly entrenched and well supported by
policy and practical considerations, the right is not absolute.” In re Orion Pictures Corp., 21 F.3d
24, 27 (2d Cir. 1994). “Redaction may be appropriate to protect confidential information.”
Fairstein v. Netflix, Inc., No. 20-CV-8042 (PKC), 2023 WL 6164293, at *1 (S.D.N.Y. Sept. 21,
2023).
UWorld seeks to file under seal ECF No. 15. UWorld inadvertently revealed the identity of a third
party, which is not publicly known, and Archer Review must keep confidential. This information
is irrelevant to the Court’s decision on sealing (and irrelevant to the dispute for which the sealing
is requested). The Court in the underlying action, UWorld, LLC fka USMLEWorld, LLC v. USMLE
Galaxy, LLC DBA Archer Review and Tart Labs, No. 3:23-cv-00447 (N.D. Tex.), has ordered
sealing of similar information (See ECF No. 105). Accordingly, UWorld respectfully requests that
the Court seal ECF No. 15 and allow UWorld to file Exhibit A as a replacement thereof.

Norton Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.

297188374.1

Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright
South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps
coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are
available at nortonrosefulbright.com.

Case 1:25-mc-00079-MKV

Document 20

Filed 03/11/25

Page 2 of 2

Honorable Mary K. Vyskocil
March 11, 2025
Page 2

Respectfully submitted,

/s/ Sean M. Topping
Sean M. Topping

GRANTED
ECF 15 SHALL BE SEALED PROVISIONALLY
UNTIL THE RESOLUTION OF PENDING
MOTION AT ECF 1 & 12.

Partner

SO ORDERED.

3/11/2025

297188374.1