ChemImage Corporation v. Johnson & Johnson

Opinion

SS Patte rso n www.pbwt.com Belknap Application GRANTED, subject to reconsideration in the event that any May 3, 2024 party or third party files a motion to Rachel Sherman unseal a particular document or Partner 212) 336-2147 documents. The Clerk is directed to nara bwt.com terminate ECF No. 24. Hon. Jesse M. Furman SO ORDERED. United States District Court Southern District of New York 40 Foley Square, Courtroom 1105 New York, NY 10007 May 82024 Re: □ Chemlmage Corp. v. Johnson & Johnson et al., No. 1:24-cv-2646 (JMF) Letter Motion Seeking Leave to File Document in Redacted Form Dear Judge Furman: We represent Defendants Johnson & Johnson and Ethicon, Inc. (together, “Defendants”). We write pursuant to this Court’s Standing Order 19-MC-583, Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions, and Rule 7(C) of the Court’s Individual Rules and Practices in Civil Cases to respectfully seek leave to file the Memorandum of Law in Support of Defendants’ Partial Motion to Dismiss in redacted form on ECF. The Memorandum contains reference to certain cash consideration and milestone payment and royalty amounts that the Court previously allowed the parties to redact from the Complaint and its exhibit. See Dkt. 16. As the Court previously held, these redactions remain narrowly tailored to protect competitive business information that courts routinely seal. See, e.g., Regeneron Pharms., Inc. v. Novartis Pharma AG, No. 1:20-cv-05502, 2021 WL 243943, at *1 (S.D.N.Y. Jan. 25, 2021). Defendants respectfully request that the portions of the Memorandum identified above and highlighted in both the publicly-filed and filed-under-seal versions accompanying this submission be permitted to be filed in redacted form. Respectfully submitted, /s/ Rachel Sherman Rachel Sherman Counsel for Defendants Johnson & Johnson and Ethicon, Inc.

Patterson Belknap Webb & TylerLLP 1133 Avenue of the Americas, New York, NY 10036 T 212.336.2000 F 212.336.2222

MPaagye 3, 2024

cc: All counsel of record (via ECF) 2