Subramanian v. Lupin Inc.

Opinion

brownrudnick USDC SDNY ANTHONY J. BOCCAMAZZO DOCUMENT direct dial: 860.509.6568 ELECTR fax: 860.509.6655 ONICALLY FILED aboccamazzo@brownrudnick.com DOC #: DATE FILED: 7/16/2020 July 15, 2020

VIA ECF DERED Hon. Katharine H. Parker, U.S.M.J. SO ZZ Daniel P. Moynihan U.S. Courthouse + 500 Pearl Street, Room 1950 alin New York, New York 10007 HON. KATHARINE H. PARKER UNITED STATES MAGISTRATE JUDGE RE: Veerappan Subramanian y. Lupin, Inc. 07/16/2020 Civ. Action No. 17-5040-RA-KH

Dear Judge Parker: Pursuant to your Honor’s Rules, Defendant_and Counterclaim Plaintiff Lupin, Inc. (“Lupin”) requests that the Court accept under seal Lupin’s opposition to the Sellers’ July 10, 2020 motion to compel (the “Opposition’’), as well as Exhibits A and B appended to the Opposition. The Opposition and Exhibits A and B thereto make reference to certain confidential information with respect to settlement discussions of the Euticals Action, which has been redacted from the publicly filed version of the Opposition. The information redacted from the Opposition is of a kind that has not been historically open to the press and the general public, and, thus, should be filed under seal in accordance with the experience and logic test. See Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132 (2d Cir. 2016).

Respectfully, BROWN RUDNICK LLP

/s/Anthony J. Boccamazzo Anthony J. Boccamazzo