Order granting 50 Letter Motion to Seal. Application Granted. So Ordered — United States v. Visa Inc. (Dkt. 55, S.D.N.Y. No. 1:24-cv-07214)

Summary

Document 55 in United States v. Visa, Inc., Case No. 1:24-cv-07214, Southern District of New York, reproduces a January 19, 2025 letter to Judge Koeltl in which the United States seeks leave to file under seal its Opposition to Visa's Motion to Dismiss and a redacted version publicly. It states that the opposition contains information produced by Visa in the pre-Complaint Investigation and designated Highly Confidential under the Protective Order. It states that counsel conferred on January 16, that the United States notified Visa it would move to seal discussion of Visa's contracts with third parties, and that the United States does not oppose sealing the materials redacted in its Opposition. The notation APPLICATION GRANTED and SO ORDERED appears on the page. The letter is signed /s/ Aaron Teitelbaum.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Text recognized from a scanned document; may contain errors.

Case 1:24-cv-07214-JGK Document55-~ Filed 01/20/25 Page 1of2
Case 1:24-cv-07214-JGK Document50_ Filed 01/19/25 Page1of2

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.

l APPLICATION GRANTED
// SO ORDERED

// [ / : ohn G. Koeltl, U.S.D.J.
Case 1:24-cv-07214-JGK Document55-~ Filed 01/20/25 Page 2 of 2
Case 1:24-cv-07214-JGK Document50 Filed 01/19/25 Page 2of2

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


File and source

File

gov.uscourts.nysd.628802.55.0.pdf

Size

2,055,003 bytes

SHA-256

e4621b28c9b3603ebd1a383537d0ae39856ed09f667e48edf6bfcb05d45b6604

Our copy

gov.uscourts.nysd.628802.55.0.pdf

Original

PACER (login required)