PLAINTIFF'S MOTION FOR LEAVE TO FILE SUMMARY JUDGMENT REPLY MEMORANDUM AND EXHIBITS UNDER SEAL

CAM FERENBACH, Magistrate Judge.

Plaintiff Federal Trade Commission ("FTC") hereby moves this Court for an Order granting the FTC leave to file its summary judgment reply memorandum, appendix, declaration, and exhibits (Docket No. 514 et seq.), under seal. The Court approved the FTC's similar request to provisionally file materials under seal with respect to the FTC's initial motion for summary judgment papers. (See Docket No. 476.) In support of this motion, the FTC states as follows:

1. On January 11, 2013, this Court entered an amended protective order, (Docket No. 308), permitting parties to designate documents and testimony as confidential, and to submit such information to the Court under seal.

2. On September 30, 2013, the FTC filed a motion for summary judgment (Docket No. 454). With the Court's permission, (Docket No. 476), the FTC filed under seal its memorandum, (Docket No. 456), and exhibits, (Docket No. 455), in support thereof.

3. On December 20, 2013, the FTC filed a reply in support of its motion for summary judgment (the "Reply"), as well as an appendix and declaration with accompanying exhibits (Docket No. 514 et seq.). Some of those papers contain confidential consumer data designated by the FTC or Defendants as confidential. In addition, the Defendants have designated nearly all of their documents, and testimony regarding those documents, as confidential.

4. Due to the breadth of the Defendants' confidential designations and the FTC's repeated references in its Reply to documents and testimony designated by Defendants as confidential, the FTC, out of an abundance of caution, seeks leave of the Court to file its entire Reply and all exhibits under seal.

5. After summary judgment briefing is concluded, the FTC intends to confer with the Defendants regarding redacting portions of its Reply and unsealing and redacting certain exhibits. The parties successfully reached an analogous, post-briefing agreement in unsealing large portions of the parties' previous briefing on the FTC's motion for preliminary injunction. (See Docket No. 283). WHEREFORE, the FTC respectfully requests leave of the Court to file its reply in support of motion forsummary judgment, appendix, declaration, and all corresponding exhibits (Docket No. 514 et seq.) under seal, with a reservation of the right to move the Court at a later date to lift the seal order in part.

IT IS SO ORDERED.