Susquehanna Securities LLC, et al. v. John Does 1 Through 100

Opinion

FRIEDMAN KAPLAN JOHN N. ORSINI jorsini@fklaw.com 212.833.1186

July 23, 2026 VIA ECF Honorable Arun Subramanian, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Susquehanna Securities LLC, et al. v. John Does 1 Through 100, No. 1:26-cv-05474 (AS) (S.D.N.Y.) Dear Judge Subramanian: This firm represents plaintiffs Susquehanna Securities LLC and Susquehanna Investment Group (“Susquehanna”) in the above-captioned action (the “Action”). We write jointly with Plaintiff-Intervenor Citadel Securities LLC (“Citadel Securities,” and together with Susquehanna, “Plaintiffs”) pursuant to Rule 11.C of the Your Honor’s Individual Practices in Civil Cases, as well as Section 6.1 of the Southern District of New York’s Electronic Case Filing Rules, and the Court’s standing order, 19-MC-00583, to respectfully request leave to file one document under seal which contains personal financial and identifying information designated confidential by non-parties pursuant to the Protective Order, dated July 16, 2026 (ECF No. 45) (the “Protective Order”).! The document Plaintiffs seek to file under seal is Exhibit A to Plaintiffs’ Certificate of Service regarding service of the Temporary Restraining Order and Order to Show Cause for a Preliminary Injunction and Granting Plaintiffs’ Ex Parte Motion for Expedited Discovery (ECF No. 10, the “Order”), and the papers on which it was granted, on individuals and entities that made the Subject Trades as defined in the Order. The information contained in Exhibit A was produced to Susquehanna by Interactive Brokers LLC (“IBKR”) and TradeUP Securities, Inc. (“TradeUP”) and includes personally identifying and financial information, including full names, home addresses, email addresses, and brokerage account numbers for all individuals and entities who were identified as engaging in the Subject Trades. IBKR and TradeUP designated such information as “Confidential” pursuant to Paragraph 3 of the Protective Order

' Your Honor’s Individual Practices in Civil Cases Rule 11.A and Rule 5.2 of the Federal Rules of Civil Procedure allow for Plaintiffs to redact certain of the information described herein, including portions of financial account numbers, home addresses, personal identifying numbers, and individual financial information without leave of the Court. For the avoidance of doubt, Plaintiffs seek leave to redact all information described herein, including names and complete account numbers and addresses. Friedman Kaplan Seiler Adelman & Robbins LLP 4914-6176-1216.1

Hon. Arun Subramanian -2- July 23, 2026

Plaintiffs seek to file Exhibit A under seal given the sensitive and personally identifying information therein. At this time, these individuals and entities have not been named by Plaintiffs as defendants in this Action, as Plaintiffs have not yet filed their amended complaint. An order sealing Exhibit A is thus imperative to protect the privacy and personal information of such individuals and entities. Courts frequently grant motions to seal such information. See, e.g., Lively v. Wayfarer Studios LLC, No. 24-CV-10049 (LJL), 2025 WL 2351013, at *2 (S.D.N.Y. Aug. 13, 2025) (granting motion to seal “personal phone numbers and email addresses and banking routing and account numbers”); Sec. & Exch. Comm'n v. Waldman, No. 17 CV. 2088 (RMB), 2019 WL 1644965, at *1 (S.D.N.Y. Feb. 14, 2019) (case allowing redaction of “(i) financial account numbers, (11) personal e-mail addresses, (111) physical home addresses”). Consistent with the applicable rules and Paragraph 6 of the Protective Order, Plaintiffs are filing herewith a public, redacted version of Exhibit A, with redactions limited to confidential information (specifically, redacting only names, account numbers, addresses and email addresses). Plaintiffs will file an unredacted copy under seal. The proposed redactions are narrowly tailored to protect only the confidential information described above, and no less restrictive alternative would adequately protect the privacy interests at stake. We thank the Court for its consideration of this request and remain available to provide any further information the Court may wish to receive. Respectfully submitted, /s/ John N. Orsini John N. Orsini

ce: All counsel of record (by ECF) The Clerk of Court is respectfully directed to terminate the motion at ECF No. 55. ORDERED.

Subramanian, U.S.D.J. July 24, 2026

Friedman Kaplan Seiler Adelman & Robbins LLP 4914-6176-1216.1