Kimera Labs Inc v. Jayashankar
- Proceeding
- district
- Area
- civil
- Panel
- Michael M. Anello (author)
Analysis
The court considered multiple motions by the parties to file discovery-related pleadings and exhibits under seal. The court denied all motions to seal in their entirety, ordering the parties to re-file the documents unsealed or with narrowly tailored redactions supported by a showing of good cause.
| What the court decided | The model |
|---|---|
Plaintiff's motions to file under seal (Dkt. Nos. 157, 169, 172) are denied.“On January 19, 2024, the Court issued oral rulings denying Plaintiff’s motions to file under seal in their entirety Plaintiff’s Opposition to Defendant Exocel Bio Inc.’s Motion to Quash [Dkt. No. 157] and Plaintiff’s Opposition to Defendants’ Motion to Compel [Dkt. No. 169]... Accordingly, Plaintiff's motion to seal the re-filed exhibit is also DENIED.” | agree with court The court applied the 'good cause' standard, which is the correct standard for discovery-related filings that are only tangentially related to the merits. The court found the parties failed to make the required particularized showing of specific prejudice or harm, relying on the precedent that broad allegations are insufficient. The decision follows from the cited law and the recited lack of specific evidence. |
Defendant's motion to file under seal (Dkt. No. 164) is denied.“The Court also issued an oral ruling denying Defendants’ motion to file under seal in its entirety Defendants’ Motion to Compel [Dkt. No. 164].” | agree with court Similar to the plaintiff's motions, the defendant failed to demonstrate good cause for sealing the entire motion to compel. The court correctly applied the 'good cause' standard for discovery disputes and found the showing insufficient. |
The order itself: sound — The order correctly identifies the applicable legal standards for sealing discovery-related documents in the Ninth Circuit. It distinguishes between the 'compelling reasons' and 'good cause' standards based on the relationship of the filings to the merits. It correctly applies the 'good cause' standard to the discovery motions at issue and denies the motions because the parties failed to provide the required particularized showing of harm. The reasoning is complete and supported by binding Ninth Circuit authority.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 KIMERA LABS INC, Case No.: 21-cv-2137-MMA-DDL 12 Plaintiff, ORDER DENYING PARTIES’ 13 v. MOTIONS TO SEAL 14 EXOCEL BIO INC., RAJ [Dkt. Nos. 157, 164, 169, 172] JAYASHANKAR, ALEJANDRO 15 (ALEX) CONTRERAS, and DEB 16 HUBERS, 17 Defendants. 18 19 On January 19, 2024, the Court issued oral rulings denying Plaintiff’s motions to file 20 under seal in their entirety Plaintiff’s Opposition to Defendant Exocel Bio Inc.’s Motion to 21 Quash [Dkt. No. 157] and Plaintiff’s Opposition to Defendants’ Motion to Compel [Dkt. 22 No. 169]. The Court also issued an oral ruling denying Defendants’ motion to file under 23 seal in its entirety Defendants’ Motion to Compel [Dkt. No. 164]. For the reasons stated 24 on the record, the parties have not shown good cause to seal these documents in their 25 entirety. 26 Plaintiff also filed a motion to seal concerning a re-filed exhibit to its Opposition to 27 Defendants’ Motion to Compel. Dkt. No. 172. The Court’s ruling denying Plaintiff’s 28 motion to seal its Opposition to Defendants’ Motion to Compel also extends to all exhibits 1 || filed in support thereof. Accordingly, Plaintiff's motion to seal the re-filed exhibit is also 2 || DENIED. 3 By not later than January 26, 2024, the parties must re-file their respective 4 ||pleadings. The parties may move to seal specific portions of those pleadings consistent 5 || with the principles that a request to seal a record must be “narrowly tailored” and must be 6 ||supported by a showing of “good cause.” See In re Mahltig Mgmt. Und 7 || Beteiligungsgesellschaft MBH, No. 18-mc-80037 NC, 2018 WL 11198061, at *6 (N.D. 8 ||Cal. Apr. 24, 2018). Courts apply the “compelling reasons” standard to motions to seal 9 || filings that are “more than tangentially related to the merits of a case.” Jd., citing Ctr. For 10 || Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1101-02 (9th Cir. 2016). But where, as 11 |/here, the filings are “only tangentially related to the merits” of the case, a court may seal 12 || the filings “upon a lesser showing of ‘good cause.’” I/d., citing Ctr. For Auto Safety, 809 13 || F.3d at 1097. “The ‘good cause’ standard requires a “particularized showing’ that ‘specific 14 || prejudice or harm will result’ if the information is disclosed. .. . ‘Broad allegations of 15 ||harm, unsubstantiated by specific examples of articulated reasoning’ will not suffice.” 16 || Jd. at *6 (citations omitted). 17 IT IS SO ORDERED. 18 || Dated: January 23, 2024 pile 71 United States Magistrate Judge 22 23 24 25 26 27 28