Opinion
Civ. Action 1:21-cv-08319
12-16-2022
ZOETIS, INC., Plaintiff, v. BOEHRINGER INGELHEIM VETMEDICA, GmbH, a German Corporation, Defendant.
Philip L. Hirschhorn Keith A. Jones PANITCH SCHWARZE BELISARIO & NADEL LLP Counsel for Plaintiff Zoetis, Inc.
Philip L. Hirschhorn Keith A. Jones PANITCH SCHWARZE BELISARIO & NADEL LLP Counsel for Plaintiff Zoetis, Inc.
PLAINTIFF'S SUBMISSION OF REDACTED SUMMARY JUDGMENT MATERIALS
Hon. Denise L. Cote
Pursuant to the Court's December 9, 2022 Order (ECF 66), Plaintiff Zoetis, Inc. (“Zoetis”) respectfully submits public, redacted versions of its summary judgment materials, attached hereto.
Zoetis's opening brief and Exhibit 1 (both filed at ECF 49) are submitted herewith with limited redactions that are justified because they relate to specifically negotiated terms of the license agreement at issue between the parties, the terms of which are confidential between the parties and reflect competitively sensitive licensing information. Moreover, the redactions relate to specific licensing terms that are not disputed in the present case, and therefore do not form the basis of the parties' arguments or the Court's Opinion.
Also attached are versions of Exhibits 6-9,11-22, and 32 with limited redactions. Each of these exhibits contains personally identifiable information of the parties' employees (such as phone numbers and email addresses) that are not relevant to the present dispute and should not be publicly disclosed. Exhibits 11-22 and 32 also contain information regarding the licensing terms as described in the prior paragraph.
Finally, Zoetis also attaches copies of its Local Rule 56.1 statement (ECF 51), its reply brief (ECF 63), and its counter-statement to Defendant's Local Rule 56.2 statement (ECF 65), all in unredacted form.