Solid 21, Inc. v. Richemont North America, Inc.

S.D. New York

Solid 21, Inc. v. Richemont North America, Inc.

District Court, S.D. New York·Decided October 8, 2021·No. 1:19-cv-01262·Unknown

Opinion

HECHTPARTNERS David L. Hecht —— LLP Partner P: (212) 851-6821 E: dhecht@hechtpartners.com VIA ECF October 7, 2021 Hon. Lorna G. Schofield United States District Judge United States District Court 40 Foley Square New York, New York 10007 RE: Solid 21, Inc. v. Richemont North America, Inc. et al, Case No. 1:19-cv-01262-LGS Dear Judge Schofield, We represent Plaintiff Solid 21, Inc. (“Solid 21”) in the above captioned matter. Solid 21’s opposition to Defendant’s Motion for Summary Judgment as well as Plaintiff’s Cross-Motion for Summary Judgment is due today, October 7, 2021. See ECF No. 134. We respectfully request that permission to file under seal Exhibit 1 and Exhibit 2 to the Hecht Declaration filed in support of Plaintiff's Opposition to Defendant’s Motion for Summary Judgment and Cross-Motion for Summary Judgment. Consistent with Section I(D)(i11) of this Court’s Individual Rules, these documents will be filed under seal on ECF and electronically related to this letter motion. Counsel for Plaintiff files these documents fully under seal in an abundance of caution, as Defendant has previously designated these documents as Attorney’s Eyes Only, Highly Confidential, or Confidential pursuant to the Protective Order.

Solid 21 thanks the Court for its consideration in this matter. Respectfully Submitted, /s/ David L. Hecht David L. Hecht Hecht Partners LLP 125 Park Avenue, 25" Floor New York, NY 10017 Tel: 212-851-6821 Email: dhecht@hechtpartners.com Attorney for Plaintiff Solid 21, Inc. cc. Counsel of Record (via ECF)

125 Park Avenue, 25th Floor, New York, NY 10017

October 7, 2021 Page 2

Appendix identifying all parties and attorneys of record who should have access to the sealed documents David L. Hecht, Counsel for Plaintiff Yi Wen Wu, Counsel for Plaintiff Andrew J. Lorin, Counsel for Plaintiff John P. Margiotta, Counsel for Defendant David Donahue, Counsel for Defendant Laura E. Popp-Rosenberg, Counsel for Defendant Daniel M. Nuzzaci, Counsel for Defendant Emily S. Weiss, Counsel for Defendant Sydney L. Kipen, Counsel for Defendant Defendant shall file a response by October 15, 2021, stating whether they seek to seal Exhibits 1 and 2 to the Hecht Declaration. If Defendant seeks to seal those documents, Defendant shall provide the basis for sealing in accordance with the three-part test in Lugosch. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). If Defendants believe redactions are appropriate, they shall also submit proposed redactions. So Ordered. Dated: October 8, 2021 New York, New York LORNA G. SCHOFIEL UNITED STATES DISTRICT JUDGE

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HECHTPARTNERS David L. Hecht —— LLP Partner P: (212) 851-6821 E: dhecht@hechtpartners.com VIA ECF October 7, 2021 Hon. Lorna G. Schofield United States District Judge United States District Court 40 Foley Square New York, New York 10007 RE: Solid 21, Inc. v. Richemont North America, Inc. et al, Case No. 1:19-cv-01262-LGS Dear Judge Schofield, We represent Plaintiff Solid 21, Inc. (“Solid 21”) in the above captioned matter. Solid 21’s opposition to Defendant’s Motion for Summary Judgment as well as Plaintiff’s Cross-Motion for Summary Judgment is due today, October 7, 2021. See ECF No. 134. We respectfully request that permission to file under seal Exhibit 1 and Exhibit 2 to the Hecht Declaration filed in support of Plaintiff's Opposition to Defendant’s Motion for Summary Judgment and Cross-Motion for Summary Judgment. Consistent with Section I(D)(i11) of this Court’s Individual Rules, these documents will be filed under seal on ECF and electronically related to this letter motion. Counsel for Plaintiff files these documents fully under seal in an abundance of caution, as Defendant has previously designated these documents as Attorney’s Eyes Only, Highly Confidential, or Confidential pursuant to the Protective Order.

Solid 21 thanks the Court for its consideration in this matter. Respectfully Submitted, /s/ David L. Hecht David L. Hecht Hecht Partners LLP 125 Park Avenue, 25" Floor New York, NY 10017 Tel: 212-851-6821 Email: dhecht@hechtpartners.com Attorney for Plaintiff Solid 21, Inc. cc. Counsel of Record (via ECF)

125 Park Avenue, 25th Floor, New York, NY 10017

October 7, 2021 Page 2

Appendix identifying all parties and attorneys of record who should have access to the sealed documents David L. Hecht, Counsel for Plaintiff Yi Wen Wu, Counsel for Plaintiff Andrew J. Lorin, Counsel for Plaintiff John P. Margiotta, Counsel for Defendant David Donahue, Counsel for Defendant Laura E. Popp-Rosenberg, Counsel for Defendant Daniel M. Nuzzaci, Counsel for Defendant Emily S. Weiss, Counsel for Defendant Sydney L. Kipen, Counsel for Defendant Defendant shall file a response by October 15, 2021, stating whether they seek to seal Exhibits 1 and 2 to the Hecht Declaration. If Defendant seeks to seal those documents, Defendant shall provide the basis for sealing in accordance with the three-part test in Lugosch. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). If Defendants believe redactions are appropriate, they shall also submit proposed redactions. So Ordered. Dated: October 8, 2021 New York, New York LORNA G. SCHOFIEL UNITED STATES DISTRICT JUDGE

Solid 21, Inc. v. Richemont North America, Inc., (S.D.N.Y. 2021).

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