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Case 2:14-cv-01523-GEB-AC Document 12 Filed 06/26/14 Page 1 of 3

1 MORGAN, LEWIS & BOCKIUS LLP


Benjamin P. Smith, State Bar No. 197551
2 Christopher J. Banks, State Bar No. 218779
Dennis J. Sinclitico, Jr., State Bar No. 240260
3 One Market, Spear Street Tower
San Francisco, CA 94105-1126
4 Tel: 415.442.1000
Fax: 415.442.1001
5
Attorneys for Plaintiff
6 ENTERCOM CALIFORNIA LLC
7

8 UNITED STATES DISTRICT COURT


9 EASTERN DISTRICT OF CALIFORNIA
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ENTERCOM CALIFORNIA LLC, (F/K/A Case No. 2:14-cv-01523 GEB AC
11 ENTERCOM SACRAMENTO, LLC),
NOTICE OF REQUEST TO SEAL
12 Plaintiff, DOCUMENTS AND FILE REDACTED
VERSIONS OF DOCUMENTS
13 vs. SUBMITTED IN SUPPORT OF
PLAINTIFFS MOTION FOR
14 WILLIAMS BROADCASTING TEMPORARY RESTRAINING ORDER
INCORPORATED,
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Defendant.
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS
Case 2:14-cv-01523-GEB-AC Document 12 Filed 06/26/14 Page 2 of 3

1 Pursuant to Local Rules 140 and 141, Entercom California LLC (Entercom) hereby

2 submits its Request to Seal Documents and File Redacted Versions of the following documents

3 containing confidential business information submitted in support of Plaintiffs Application for

4 Preliminary Injunction (filed concurrently herewith) and requests that the Court authorize

5 Entercom to redact the documents as described herein:

6 1. Entercoms Complaint;

7 2. Entercoms Memorandum of Points and Authorities in Support of Application for

8 a Temporary Restraining Order and Order to Show Preliminary Injunction;

9 3. Declaration of Michael Dash In Support of Entercoms Application for a


10 Temporary Restraining Order and Order to Show Preliminary Injunction a

11 Preliminary Injunction and exhibits thereto.

12 The Licensing Agreement at the heart of this dispute contains a confidentiality provision

13 regarding the specific provision of the Agreement itself and also requires each party maintain as

14 confidential financial information that it receives about the other. Each of these documents

15 contains excerpts of or reference to the contract as well as financial information and filing the

16 such documents publicly would violate the Licensing Agreements confidentiality provision.

17 Accordingly, Plaintiff respectfully requests that the Court grant Entercoms permission to file

18 redacted versions of the above referenced documents in the public docket and to have the

19 unredacted versions of these documents filed under seal.


20 In light of the contractual requirement to maintain the confidentiality of the License

21 Agreement, Entercom submits that good cause exists to grant this request.

22 In accordance with Local Rule 140, Entercom will submit this Notice, Request to Seal,

23 Proposed Order, and redacted and unredacted versions of the documents sought to be sealed via

24 electronic mail to the Court Clerk upon filing of the Complaint. Entercom has given notice to

25 Defendant Williams Broadcasting Incorporated (Williams) as provided for in the Licensing

26 Agreement as well as to attorney Kevin Hughley, who has represented Williams in recent

27 negotiations. Entercom also intends to submit these documents to the Court via email as soon as
28 this matter is assigned to a judge.
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 1 PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS
Case 2:14-cv-01523-GEB-AC Document 12 Filed 06/26/14 Page 3 of 3

1 Dated: June 26, 2014 MORGAN, LEWIS & BOCKIUS LLP

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By /s/
3 Benjamin P. Smith
Christopher J. Banks
4 Dennis J. Sinclitico, Jr.
Attorneys for Plaintiff
5 ENTERCOM CALIFORNIA LLC
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8 DB1/ 79833024.1

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 2 PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS