GlobalFoundries U.S. Inc. v. International Business Machines Corporation

Filing 76

ORDER granting 71 Letter Motion to Seal. Granted. so ordered. (Signed by Judge Kenneth M. Karas on 9/22/2023) (rro)

Case 7:23-cv-03348-KMK-AEK Document 71 Filed 09/22/23 Page 1 of 1
Clement J. Naples

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u\., •

LATHAM&WATK IN SLLP

September 22, 2023

VIAECF
Hon. Kenneth M. Karas, U.S.D.J.
The Hon. Charles L. Brieant Jr.
Federal Building and United States Courthouse
300 Quarropas St.
White Plains, NY 10601-4150

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Washington , D.C.

Re: Globa!Foundries US. Inc. v. Intl. Bus. Machines Corp., No. 23-CV-03348-KMK-AEK
Letter Motion to Seal

Dear Judge Karas:
We write on behalf of Plaintiff GlobalFoundries U.S. Inc. ("GF") to request an order
authorizing: (1) the public filing of a minimally-redacted version of GF's September 22, 2023
opposition to Defendant International Business Machines Corporation's ("IBM") Motion to
Dismiss (the "Opposition"), and (2) the sealed filing of Exhibit C thereto.
On May 11, 2023, the Court granted GF's application to permanently maintain the sealed,
unredacted Complaint that was originally filed in Case No. 23-MC-111. 1 (ECF No. 37.) The
minimal redactions in GF's Opposition quote the sealed parts of that Complaint or the terms of the
parties' confidential agreements that formed the basis of GF's initial sealing request, which the
Court granted in Order No. 37. Exhibit C is a copy of one of the parties' confidential agreements,
and it contains the parties' confidential business information.
We thank the Court for its consideration.
Granted.

Respectfully submitted,

o Ordered.
9/22/23

~

Isl Clement J. Naples
Clement J. Naples

cc: All counsel of record (via ECF)

1

GF incorporates bl reference all ar~uments made in its motion to permanently seal the

Complaint. ECF No. 26.