`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SEAGEN INC.,
`
`Plaintiff,
`
`v.
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`DAIICHI SANKYO CO., LTD.,
`
`Defendant.
`
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`)
`)
`)
`)
`)
`)
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`)
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`CASE NO. 2:20-cv-00337-JRG
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`JURY TRIAL DEMANDED
`
`DEFENDANT’S UNOPPOSED MOTION TO FILE UNDER SEAL ITS RULE 12(B)
`MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION AND
`LACK OF PERSONAL JURISDICTION
`
`In accordance with Local Rule CV-5(a)(7), Defendant Daiichi Sankyo Company, Limited
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`(“Defendant”) hereby submits its Unopposed Motion to File under Seal its Rule 12(b) Motion to
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`Dismiss for Lack of Subject Matter Jurisdiction and Lack of Personal Jurisdiction as well as
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`supporting declarations. Defendant’s Motion to Dismiss and supporting declarations contain
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`confidential and proprietary information from Defendant and third parties. Because a protective
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`order has not yet been entered in this action, Defendant respectfully requests the Court enter an
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`order permitting Defendant to file under seal its Motion to Dismiss and supporting declarations.
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`Plaintiff Seagen Inc. does not oppose Defendant’s Motion.
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`- 1-
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`
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`Case 2:20-cv-00337-JRG Document 21 Filed 01/05/21 Page 2 of 3 PageID #: 57
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`Dated: January 5, 2021
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`Respectfully submitted,
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`
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`/s/ Deron R. Dacus
`
`Deron R. Dacus
`State Bar No. 00790553
`The Dacus Firm, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, Texas, 75701
`+1 (903) 705-1117
`+1 (903) 581-2543 facsimile
`ddacus@dacusfirm.com
`
`J. Mark Mann
`State Bar No. 12926150
`mark@themannfirm.com
`MANN | TINDEL | THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Attorneys for Defendant Daiichi
`Sankyo Company, Limited
`
`OF COUNSEL:
`
`Preston K. Ratliff II
`Joseph M. O’Malley, Jr.
`Ashley N. Mays-Williams
`Paul Hastings LLP
`200 Park Avenue
`New York, NY 10166
`(212) 318-6000
`
`Attorneys for Defendant Daiichi
`Sankyo Company, Limited
`
`- 2-
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`
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`Case 2:20-cv-00337-JRG Document 21 Filed 01/05/21 Page 3 of 3 PageID #: 58
`
`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to have
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`consented to electronic service are being served with a copy of this document via the Court’s
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`CM/ECF system per Local Rule CV-5(a)(3) on January 5, 2021.
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`
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`/s/ Deron R. Dacus
`
`
`
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