Opinion

Google LLC v. Dmitry Starovikov

Court
District Court, S.D. New York
Filed
Dec 10, 2021
Cited by
0 cases

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

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xfie/ gf

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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