PLAINTIFF'S MOTION TO FILE COMPLAINT AND EXHIBITS UNDER SEAL; [PROPOSED] ORDER

VALERIE P. COOKE, District Judge.

Plaintiff Samick Musical Instruments Co., Ltd. ("Plaintiff" or "Samick") hereby moves this Court for an order sealing Plaintiff Samick's Complaint and Exhibits. These documents are filed concurrently with this Motion.

In January 2010, Plaintiff Samick and QRS Music Technologies, Inc. ("Defendant QRS") entered into an Agreement. See December 1, 2014 declaration of Matthew D. Francis, ¶ 2. This Agreement forms the basis for the majority of the claims being presently asserted by Plaintiff Samick against Defendant QRS. Id. The 2010 Agreement contains a strict confidentiality provision prohibiting disclosure of the terms of the 2010 Agreement and its accompanying Exhibits to any third party. Id.

Seeking to honor this Agreement and not breach the terms of the confidentiality provision, Plaintiff seeks permission to file the full version of the Complaint, the 2010 Agreement and its Attachments under seal. Id. at ¶ 3. A redacted version of the Complaint with non-confidential Exhibits A and B has been filed to initiate this lawsuit. Id. As stated above, the Complaint has been redacted because many of the facts and causes of action refer directly to the terms of the 2010 Agreement. Id.

LR 10-5(b) provides in part ". . . papers filed with the Court under seal shall be accompanied by a motion for leave to file those documents under seal, and shall be filed in accordance with the Court's electronic filing procedures."

In good faith, seeking to honor and not breach the terms of the parties' 2010 Agreement, Plaintiff Samick requests that this Court grant its Motion to file the un-redacted Complaint, 2010 Agreement and Exhibits under seal.

IT IS SO ORDERED.

DECLARATION OF MATTHEW D. FRANCIS

I, Matthew D. Francis, do hereby declare and state as follows:

1. I am a partner at the law firm of Watson Rounds located at 5371 Kietzke Lane, Reno, Nevada 89511. This declaration is based upon my personal knowledge, and is made in support of Plaintiff Samick Musical Instruments Co., Ltd. ("Plaintiff" or "Samick") Motion to File Complaint and Exhibits Under Seal.

2. In January 2010, Plaintiff Samick and QRS Music Technologies, Inc. ("Defendant QRS") entered into an Agreement. This Agreement forms the basis for the majority of the claims being presently asserted by Plaintiff Samick against Defendant QRS. The 2010 Agreement contains a strict confidentiality provision prohibiting disclosure of the terms of the 2010 Agreement and its accompanying Exhibits to any third party.

3. Seeking to honor this Agreement and not breach the terms of the confidentiality provision, Plaintiff seeks permission to file the full version of the Complaint, the 2010 Agreement and its Attachments under seal. A redacted version of the Complaint with non-confidential Exhibits A and B has been filed to initiate this lawsuit. As stated above, the Complaint has been redacted because many of the facts and causes of action refer directly to the terms of the 2010 Agreement.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.