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PLAINTIFF’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE NO. 3:24-cv-03975
WILLKIE FARR & GALLAGHER LLP
Alexander L. Cheney (SBN 302157)
acheney@willkie.com
333 Bush Street
San Francisco, CA 94104
(415) 858-7400
Stuart R. Lombardi (pro hac vice forthcoming)
slombardi@willkie.com
787 7th Avenue
New York, NY 10019
(212) 728-8000
Joshua S. Levy (pro hac vice forthcoming)
jlevy@willkie.com
1875 K Street, N.W.
Washington, DC 20006-1238
(202) 303-1000
Attorneys for Petitioner
Oto Analytics, LLC
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
OTO ANALYTICS, LLC,
Petitioner,
v.
BENWORTH CAPITAL PARTNERS
LLC,
Respondent.
Case No. 3:24-cv-03975
PETITIONER’S ADMINISTRATIVE
MOTION TO CONSIDER WHETHER
ANOTHER PARTY’S MATERIAL
SHOULD BE SEALED
Case 4:24-cv-03975-AMO Document 5 Filed 07/01/24 Page 1 of 3
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PLAINTIFF’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE NO. 3:24-cv-03975
Pursuant to Civil Local Rule 79-5(f), Petitioner Oto Analytics, LLC (f/k/a Oto Analytics,
Inc., d/b/a Womply) (“Womply”) respectfully submits this Administrative Motion To Consider
Whether Another Party’s Material Should Be Sealed (“Administrative Motion”) in connection with
its Petition To Confirm Arbitration Award And For Entry of Judgment (“Petition”).
Civil Local Rule 79-5(f) provides that “[f]or any document a party (‘Filing Party’) seeks to
seal because that document has been designated as confidential by another party or non-party, (the
‘Designating Party’), the Filing Party must . . . file an Administrative Motion to Consider Whether
Another Party’s Material Should Be Sealed,” so that “the Designating Party [can] file a statement
and/or declaration” justifying any sealing or redaction. In accordance with Civil Local
Rule 79-5(f), Petitioner submits this Administrative Motion because its Petition and accompanying
Declaration of Alexander L. Cheney (“Cheney Declaration”) and exhibits contain certain
information that Respondent Benworth Capital Partners LLP (“Benworth”) has claimed or may
claim is confidential. Benworth has the burden to justify its claims of confidentiality and to
establish that the designated information is sealable. Civ. L.R. 79-5(f)(3) & (c)(1). In the interim,
Womply is provisionally submitting the following information under seal:
Docket No.
Document
Page/Line Nos.
1
Petition to Confirm Arbitration Award and For
Entry of Judgment
Page 9, Line(s) 15–19
1-1
Cheney Declaration
Page 2, Line(s) 19–24
1-4
Exhibit 3 to the Cheney Declaration, Corrected
Final Award, dated June 26, 2024
Portions of pages 16–17, 24,
25–29, 37–39, 44–45, 50–51,
53
1-8
Exhibit 7 to the Cheney Declaration, Arbitration
Order, dated January 17, 2023
Portions of pages 2–4
1-9
Exhibit 8 to the Cheney Declaration, Arbitration
Order, dated January 31, 2023
Portions of page 1–2
Case 4:24-cv-03975-AMO Document 5 Filed 07/01/24 Page 2 of 3
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PLAINTIFF’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE NO. 3:24-cv-03975
WHEREFORE, Womply respectfully submits this Administrative Motion pursuant to Civil
Local Rule 79-5, and hereby notifies Benworth of its burden to establish that the designated material
is sealable if Benworth seeks to have the material sealed. In accordance with Civil Local
Rule 79-5(e), unredacted versions of these documents accompany this Administrative Motion.
Date: July 1, 2024
WILLKIE FARR & GALLAGHER LLP
By: /s/ Alexander L. Cheney
Alexander L. Cheney
Stuart R. Lombardi (pro hac vice
forthcoming)
Joshua S. Levy (pro hac vice forthcoming)
Attorneys for Petitioner
Oto Analytics, LLC
Case 4:24-cv-03975-AMO Document 5 Filed 07/01/24 Page 3 of 3