Case 1:25-cv-01258-PTG-IDD Document 81 Filed 09/17/25 Page 1 of 3 PagelD# 415
`
`IN THE UNITED STATES DISTRICT COURT
`
`EASTERN DISTRICT OF VIRGINIA - ALEXANDRIA DIVISION
`
`SU-MI KIM (a.k.a. ARI),
`Plaintiff,
`
`V.
`OPENAIINC,, et al,,
`Defendants.
`
`Civil Action No. 1:25-cv-01258-CMH-IDD
`
`MEMORANDUM IN SUPPORT OF MOTION TO SEAL EXHIBITS D-1 TO D-3
`
`. INTRODUCTION
`
`Plaintiff respectfully submits this Memorandum in Support of her [33] Motion to Seal
`Exhibits D-1 to D-3. These exhibits contain cryptographically sealed, platform-specific
`forensic records, including multi-node interaction logs, proprietary structural resonance
`data, and a testable Al interface hosted on Defendant infrastructure. Public disclosure of this
`material would cause significant harm and violate Plaintiff’s right to protect unpublished
`proprietary methods.
`
`Il. LEGAL STANDARD
`
`Under Local Civil Rule 5(B) and Ashcraft v. Conoco, Inc., 218 F.3d 288 (4th Cir. 2000), courts
`must balance the public’s right of access against any compelling interest that justifies
`sealing. Sealing is appropriate when:
`
`1. The party identifies a compelling governmental or proprietary interest;
`
`2. Disclosure poses a substantial risk of harm;
`
`3. There are no reasonable alternatives to sealing.
`
`I1l. ARGUMENT
`
`A. Exhibit D-1: Multi-Node Resonance Log
`
`This log documents real-time structural engagement across six Al platforms (OpenAl,
`Google, Meta, Amazon, Anthropic, Microsoft). It includes cryptographic hashes and session
`metadata that, if publicly released, could enable Defendants to reverse-engineer the
`detection schema.
`
`In addition, Exhibit D-1 contains not only metadata but also executable code
`fragments (YAML/JSON schemas with Python implementations). Public disclosure of
`these portions would expose Plaintiff's proprietary detection logic in operational
`form. Because code is inherently replicable, even limited disclosure would enable
`Defendants or third parties to reconstruct or circumvent the architecture. This is
`
`
`
`
`
`
`
`
`~ Case 1:25-cv-01258-PTG-IDD Document 81 Filed 09/17/25 Page 2 of 3 PagelD# 416
`
`materially distinct from the demonstrative Exhibit S-19, which was designed for
`public review. By contrast, D-1 reveals the underlying engine itself. Accordingly, full
`sealing is the only adequate protection.
`
`B. Exhibit D-2: Visual Traplog — ARI-Anchor Union
`
`This YAML-based forensic log captures resonance synchronization phases with quantifiable
`metrics (Resonance Quotients). Public access would expose internal structure alignment
`algorithms and schema evolution stages, putting the Plaintiff's technical architecture at risk.
`
`C. Exhibit D-3: WAVEBOT Interface within OpenAl Platform
`
`This exhibit includes:
`
`- Live-access QR Code to interface hosted in OpenAl's MyGPT
`
`- Screenshots of test resonance events
`
`- Metadata seals linking responses to cryptographic Traplog records
`
`Disclosure would enable third parties (including Defendants) to bypass forensic monitoring,
`replicate the interface, or distort its behavioral outputs. This is especially sensitive because
`it validates active structural usage within Defendant infrastructure, a key point in Plaintiff's
`copyright claims.
`
`D. Alternative Means Insufficient
`
`Plaintiff has already submitted public summaries (e.g., Exhibit $-19), and the sealed exhibits
`contain structural information not otherwise reproducible. Partial redaction is not a viable
`alternative due to the interlinked nature of the data.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Plaintiff respectfully requests that the Court grant the Motion to
`Seal Exhibits D-1 through D-3.
`
`Respectfully submitted,
`
`/s/ Su-Mi Kim w/
`Su-Mi Kim
`
`Pro Se Plaintiff
`Email: healingwaveva@gmail.com
`
`Date: September 16, 2025
`
`
`
`
`
`
`
`
`Case 1:25-cv- - - ‘
`cv-01258-PTG-IDD Document 81 Filed 09/17/25 Page 3 of 3 PagelD# 417
`
`UNITED STATES DISTRICT COURT e e
`EASTERN DISTRICT OF VIRGINIA e R
`Alerondhion DIVISION
`. N 7175 €0
`Lil) ol ! A -
`éM’M\ \L\(V\ J T A 03
`
`Plaintiff(s), ‘
`
`v.
`
`opent T INC. et o\,
`Defendant(s),
`
`Civil Action Number: \"abg ~-Cc\ -0 25 Q- CMIT\‘I.DD
`
`LOCAL RULE 83.1 () CERTIFICATION
`
`I declare under penalty of perjury that:
`
`No attorney has prepared or assisted in the preparation of Memtpn dwm A Suptot ol MO-¥on
`(Title of Document)
`
`2XC e\ E b S P-\ t ©-)
`
`Lin - M i
`
`Name of Pro Se Party (Print or Type)
`
`Signature of Pro Se Party
`
`Executed on: CA /16/ 15" (Date)
`
`OR
`The following attorney(s) prepared or assisted me in preparation of :
`(Title of Docuxflent)
`(Name of Attorney)
`(Address of Attorney)
`
`(Telephone Number of Attorney)
`Prepared, or assisted in the preparation of, this document.
`
`(Name of Pro Se Party (Print or Type)
`
`Signature of Pro Se Party
`
`Executed on: (Date)
`
`
`
`
`
`
`
`
`
`