DNA Genotek Inc. v. Spectrum Solutions L.L.C.
- Proceeding
- district
- Area
- civil
- Panel
- Robert Steven Huie (author)
Analysis
Defendant Spectrum Solutions L.L.C. moved to seal Exhibit 18 and a portion of its claim construction brief, arguing that the documents contained proprietary business information. The court granted the motion, finding that Defendant demonstrated good cause to protect its competitive standing.
| What the court decided | The model |
|---|---|
Defendant's Motion to Seal (ECF No. 84) is granted.“The Court therefore GRANTS the Motion.” | agree with court The court correctly applied the Ninth Circuit's 'good cause' standard for sealing documents in connection with non-dispositive motions. The order recites that the documents contain proprietary business information and that disclosure would harm the plaintiff's competitive standing (likely a typo for defendant's, but the logic holds for the moving party). The court also noted the redactions were narrowly tailored. This satisfies the requirement of showing specific prejudice or harm. |
The order itself: sound — The order is procedurally sound. It correctly identifies the applicable legal standard (good cause for non-dispositive motions) and applies it to the specific facts presented (proprietary business information causing competitive harm). The court also addresses the tailoring of the redactions, which is a key component of a proper sealing order.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 DNA GENOTEK INC., Case No.: 21-CV-516-RSH-DDL 12 Plaintiff, ORDER GRANTING DEFENDANT’S 13 v. MOTION TO SEAL 14 SPECTRUM SOLUTIONS L.L.C., [ECF No. 84] 15 Defendant. 16 17 On February 18, 2022, Defendant filed a motion to seal documents in connection 18 with its claim construction brief (“Motion”). ECF No. 84. The Motion seeks to seal Exhibit 19 18 in support of Defendant’s claim construction brief and a portion of a single sentence in 20 that brief that describes Exhibit 18. 21 There is a presumptive right of public access to court records based upon the 22 common law and the First Amendment. See Nixon v. Warner Comm., Inc., 435 U.S. 589, 23 597 (1978); Phillips ex rel. Estates of Byrd v. General Motors Corp., 307 F.3d 1206, 1212- 24 13 (9th Cir. 2002). A party must demonstrate “good cause” when it seeks to file documents 25 under seal in connection with a non-dispositive motion. Pintos v. Pac. Creditors Ass’n, 605 26 F.3d 665, 678 (9th Cir. 2010). “For good cause to exist, the party seeking protection bears 27 the burden of showing specific prejudice or harm will result if no protective order is 28 granted.” Phillips, 307 F.3d at 1210–11. 1 The Court finds there is good cause to seal Exhibit 18 because it contains proprietary 2 || business information that could harm Plaintiff's competitive standing. There is likewise 3 ||good cause to redact Defendant’s claim construction brief. Defendant’s proposed 4 redactions are narrowly tailored to seal only the confidential information from Exhibit 18. 5 The Court therefore GRANTS the Motion. 6 IT IS SO ORDERED. fide x ¢ Pi cca 7 Dated: September 27, 2022 Hon. Robert S. Huie United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28