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 UNITED STATES DISTRICT COURTDISTRICT OF MASSACHUSETTSUNITED STATES OF AMERICA,Plaintiff,v.AARON SWARTZ,Defendant.))))))))))Case No. 11-10260-NMG

MEMORANDUM IN SUPPORT OF THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY’SMOTION TO INTERVENE AND PARTIALLY OPPOSEMOTION TO MODIFY PROTECTIVE ORDER

 The Massachusetts Institute of Technology (“MIT”) submits this memorandum of law insupport of its

motion to intervene and partially oppose the motion of the Estate of AaronSwartz (“Swartz Estate”) to modify the Protective Order entered in this matter.

Introduction

MIT files its response to protect two vital interests—the safety of its employees and otherMIT community members and the security of its computer networks. Since Aaron Swartz’sdeath on January 11, 2013, the MIT community has been the subject of threats to personal safetyand breaches to its computer network, apparently based on MIT’s involvement in the eventsrelating to Mr. Swartz’s prosecution. Despite these threats and breaches, MIT values openness,and in fact intends to release a report of its involvement in the Swartz case, along with relateddocuments. Such openness, however, must take into account and address the potential forsignificant harm to individuals and MIT’s network. Therefore, MIT opposes any modification of the Protective Order that does not contain provisions for the redaction of all identifyinginformation of any member of the MIT community as well as redactions to protect any MIT

Case 1:11-cr-10260-NMG Document 114 Filed 03/29/13 Page 1 of 21