Participated in an amicus letter brief (with the Reporters Committee and other amici) in In re Google Digital Advertising Antitrust Litigation, a multi-district litigation consolidated in the Southern District of New York.  The amicus letter relates to a second amended complaint filed by the state co-plaintiffs in Texas, et al. v. Google LLC.  The second amended complaint was filed under seal, and the publicly filed version of the pleading contains numerous redactions.  In response to the judge’s show-cause order, this letter brief argues that both the First Amendment and common law provide a presumption in favor of public access to the second amended complaint.  The letter brief points out that the public’s ability to access an unredacted version of the complaint is essential to understanding the issues presented in the litigation, which are of significant public concern.  [2021]