“Plaintiff Shenzhen Shining Bright Technology Co., Ltd. (“Plaintiff”) respectfully moves for leave to file under seal the Final Default Judgment Order submitted herewith (the “Judgment”), or, alternatively, for leave to file a narrowly redacted public version with a complete unredacted version filed under seal. In support, Plaintiff states: 1. Narrow tailoring / categories at issue. The Judgment (as drafted) contains (i) specific identifiers for certain Defaulting Defendants’ online marketplace stores (seller aliases) and (ii) directions to third-party payment and marketplace providers regarding the restraint and turnover of funds/accounts. Public disclosure of granular enforcement details risks enabling evasion, asset flight, and re-registration under new identities—undermining the Court’s injunctive and monetary relief. Prior sealing in this case. On September 24, 2025, the Court granted Plaintiff’s motion to file Appendix A to the Motion for Default Judgment under seal, and directed Plaintiff to file that appendix on the docket under seal. (See Minute Entry, Sept. 24, 2025; Sealed Appendix A filed Sept. 26, 2025.) The same evasion/asset-flight concerns apply here because the Judgment cross-references the very enforcement steps reflected in Appendix A. 3. Legal standard. While judicial records are presumptively public, L.R. 26.2 permits sealing on a showing of good cause; the Seventh Circuit recognizes protection for information that, if public, would facilitate misuse or cause competitive/economic harm. See, e.g., Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544, 546–47 (7th Cir. 2002); Goesel v. Boley Int’l (H.K.) Ltd., 738 F.3d 831, 833–34 (7th Cir. 2013). Courts also permit sealing/redaction where disclosure would impair the effectiveness of injunctive or collection remedies or reveal confidential account identifiers and enforcement details. 4. Good cause. Here, disclosure of (a) specific seller-alias mappings, (b) non-party processor routing details and account identifiers (if any appear in the final executed version), and (c) operative, step-by-step enforcement directives would materially aid evasion and frustrate the asset restraint and turnover contemplated by the Judgment. The relief is calibrated to preserve the status quo and effectuate Rule 69 proceedings; unsealing the mechanics would defeat those aims. 5. Narrow relief requested. Plaintiff does not seek wholesale secrecy of the Court’s ruling. Plaintiff proposes either: a. Filing the executed Judgment under seal and concurrently filing on the public docket a redacted version that leaves the Court’s reasoning and outcome intact while redacting only the minimal items needed to prevent evasion (seller-alias strings, unique account identifiers, nonpublic email/contact points, and any particularized processor routing data); or b. If the Court prefers, filing the Judgment publicly with targeted redactions only to the same limited fields, and lodging the unredacted version under seal. 6. Duration. Plaintiff requests that sealing (or redactions) remain in place through completion of post-judgment collection and turnover efforts as to the Defaulting Defendants, or for 180 days from entry (whichever is earlier), without prejudice to a motion to extend for good cause. 7. Compliance with L.R. 26.2. Plaintiff will (a) file a redacted public version contemporaneously, (b) file the unredacted version under seal, and (c) provide a highlighted version to chambers if required by standing order. WHEREFORE, Plaintiff respectfully requests that the Court grant leave (i) to file the Final Default Judgment Order under seal with a contemporaneous public redacted version, or, in the alternative, (ii) to file the Judgment publicly with only the limited redactions described above, with the unredacted version filed under seal; and grant such other relief as the Court deems just.”