Nike, Inc. v. Lululemon USA Inc.

Opinion

Knobbe Martens KNOBBE, MARTENS, OLSON & BEAR, LLP 2040 Main St., 14th FI., Irvine, CA 92614 T (949) 760-0404 Ali S. Razai Ali.Razai@knobbe.com December 30, 2024 GRANTED. The Clerk of Court VIA ECF respectfully directed to terminate 1 motion at ECF No. 264. Hon. Arun Subramanian Daniel Patrick Moynihan SO ORDERED. United States Courthouse 500 Pearl Street New York, NY 10007 (212) 805-0238 . Arun Subramanian, U.S.D.J. Re: Nike, Inc. v. lululemon usa inc. (Case No. 1:23-cv-00771-AS) Date: January 17, 2025 Letter Motion to File Under Seal Dear Judge Subramanian: Defendant lululemon usa, inc. (“lululemon”) respectfully requests leave to file under seal a portion of its Letter Brief Regarding the Construction of “Surrounding Textile Structure.” Specifically, lululemon requests that the Court seal three figures in the Letter Brief that contain information that □□□□□□ designated as HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY under the Protective Order, and previously requested that the Court seal. See D.I. 150-4 at adidas_lIululemon_00001365-67 (sealed filing containing the same figures); see also D.I. 217 (adidas’ Letter Brief requesting such information be sealed as trade secret manufacturing processes and competitively sensitive business information). The Court granted adidas’ previous request to seal this same information. See D.I. 250 at 2-4 (granting requests to seal). Accordingly, for the same reasons as the Court previously sealed this information, lululemon requests that it be sealed in its Letter Brief Regarding the Construction of “Surrounding Textile Structure.” See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 114 (2d Cir. 2006). lululemon’s Letter Brief Regarding the Construction of “Surrounding Textile Structure” does not contain any of lululemon’s confidential information. Very truly yours,

/s/ Ali S. Razai Ali S. Razai