The opinion
King & Spalding LLP
KING & SPALDI NG i 185 Avenue of the Americas
New York, NY 10036
Tel: +1 212 556 2100
www.ksiaw.com
Sees ae i □ Fake ae Pa Laura Harris
Ee TES PRES gee 3 Partner
ee Direct Dial: +1 252 790 5360
Direct Fax: +1 212 556 2222
lharris@kslaw.com
December 8, 2021
Via ECF
The Honorable Denise L. Cote
United States District Judge
Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, New York 10007
Re: Google LLC vy. Starevikov et al., Case No. 21-cy-10260-DLC
Dear Judge Cote:
I write on behalf of Plaintiff Google LLC (“Google”) in the above-referenced matter. On
December 6, 2021, the Court granted Google’s motion to unseal the docket and add Plaintiff
Google LLC and Defendants Dmitry Starovikov, Alexander Filippov, and Does 1-15 to the caption
as parties. Pursuant to Section 8 of the Court’s Individual Rules of Practice in Civil Cases, and
further to my December 7, 2021 letter to the court, Google respectfully requests that the Court
issue an order sealing the Declaration of Shane Huntley (the “Huntley Declaration”), filed by
Google in support of its December 2, 2021 Motion for a Temporary Restraining Order and Order
to Show Cause Regarding a Preliminary Injunction.
The Huntley Declaration references victim email addresses in paragraphs 55(a){c) and
61(a)-(c) that Defendants have used in connection with certain criminal schemes, as set forth in
paragraphs 45-61. Google secks to seal the Huntley Declaration to redact the email addresses in
order to protect those users’ privacy interests. See Royal Park Invs, SA/NV v, Deutsche Bank Nat'l
Tr. Co., 2018 WL 1750595, at *21 (S.D.N.Y. Apr. 11, 2018) (holding that information disclosing
“non-parties’ confidential information . . . [was] sufficiently sensitive to merit protection”). Along
with this motion, Google is filing a redacted version of the declaration that removes those email
addresses.
Google’s limited proposed redactions, amounting to just a handful of words, are “narrowly
tailored to protect only this sensitive [persona!] information.” Kewazinga Corp. v. Microsoft
Corp., 2021 WL 1222122, at *6 (S.D.N.Y. Mar. 31, 2021). As a result, the proposed redactions
offer meaningful protection to the privacy interests of third parties yet do not unduly infringe on
the Court’s interest in public access to information. See Burgess v. Town of Wallingford, 2012 WL
4344194, at *11 (D. Conn. Sept. 21, 2012) (ordering the redaction of email addresses and
The Honorable Denise L. Cote
December 8, 2021
Page 2
explaining that there was “minimal countervailing public interest in the disclosure of such
personally identifying information”).
For the foregoing reasons, we respectfully request the Court enter an order sealing the
Huntley Declaration. A copy of the as-filed declaration with proposed redactions highlighted 1s
filed contemporaneously with this motion, along with a redacted version,
. Respectfully submitted,
/s/ Laura Harris
Laura Harris
be
xfie/ gf