LETTER MOTION to Seal regarding United States' Opposition to Motion to Dismiss… — United States v. Visa Inc. (Dkt. 50)

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A letter motion dated January 19, 2025 from the United States to Judge Koeltl in United States v. Visa, Inc., et al., Case No. 1:24-cv-07214 (JGK-SLC), in the U.S. District Court for the Southern District of New York, Doc. 50. The United States seeks leave to file under seal its Opposition to Visa's Motion to Dismiss and to file a redacted version on the public docket. The letter states that the opposition contains information produced by Visa in the pre-Complaint Investigation that is designated as Highly Confidential under the Protective Order. It states that the United States does not oppose the sealing of the materials redacted in its Opposition. The signature line shows /s/ Aaron Teitelbaum, Lead Trial Counsel.

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Via ECF 
 
 
 
 
 
 
 
The Honorable John G. Koeltl 
January 19, 2025 
Daniel Patrick Moynihan U.S. Courthouse 
500 Pearl St., Courtroom 14A 
New York, NY 10007 
 
Re:     United States v. Visa, Inc., et al., Case No. 1:24-cv-07214 (JGK-SLC) 
 
Dear Judge Koeltl: 
 
 
Plaintiff, the United States, seeks the Court’s leave to file under seal its Opposition to 
Visa’s Motion to Dismiss and file a redacted version of the same on the public docket for the 
reasons stated below. Contemporaneous with the filing of this letter-motion, and in accordance 
with Section VI of the Court’s Individual Practices and Paragraph 40 of the Protective Order, 
ECF No. 42, the United States is (1) publicly filing on ECF a copy of the Opposition to Visa’s 
Motion to Dismiss with proposed redactions and (2) filing under seal on ECF an unredacted copy 
of the Opposition to Visa’s Motion to Dismiss with proposed redactions highlighted. 
The United States requests provisional redaction of its Opposition to Visa’s Motion to 
Dismiss because it contains information produced by Visa in the pre-Complaint Investigation 
that is designated as Highly Confidential pursuant to Paragraphs 8 and 24 of the Protective Order 
and because Visa redacted discussion of the same information in its Memorandum in Support of 
its Motion to Dismiss, asking the Court to seal that information, ECF Nos. 36, 41. The Protective 
Order and the Court’s Individual Practices govern the procedures for filing such material on the 
Court’s docket. 
Pursuant to Paragraph 40 of the Protective Order, the United States is required to move to 
seal the information designated as Highly Confidential.  In turn, Section VI of the Court’s 
Individual Practices requires that “[w]hen a party seeks leave to file sealed or redacted materials 
on the ground that an opposing party or third party has requested it, that party shall notify the 
opposing party or third party that it must file, within three days, a letter explaining the need to 
seal or redact the materials.”   
Counsel for the United States and Visa conferred on January 16, and the United States 
notified Visa that it would move to seal discussion of Visa’s contracts with third parties 
consistent with Visa’s treatment of those contracts in its Memorandum in Support of its Motion 
to Dismiss.  The United States also notified Visa of its obligation, under this Court’s Individual 
Practices, to file its own letter explaining the need to seal or redact the materials.  The United 
States does not oppose the sealing of the materials redacted in its Opposition. 
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Case 1:24-cv-07214-JGK     Document 50     Filed 01/19/25     Page 1 of 2

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Respectfully submitted, 
/s/ Aaron Teitelbaum  
Aaron M. Teitelbaum 
Lead Trial Counsel 
United States Department of Justice 
Antitrust Division 
450 Fifth Street N.W., Suite 4000 
Washington, DC 20530 
Telephone: (202) 894-4266 
Facsimile: (202) 514-7308 
Email: Aaron.Teitelbaum@usdoj.gov 
 
Attorney for Plaintiff  
United States of America 
Case 1:24-cv-07214-JGK     Document 50     Filed 01/19/25     Page 2 of 2

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