Summary
This district court order rules on the parties' omnibus motions to seal various documents and exhibits filed alongside summary judgment and sanctions motions. Applying the Ninth Circuit's 'compelling reasons' standard for summary judgment materials and the 'good cause' standard for sanctions materials, the court rejects blanket requests to seal entire documents when targeted redaction would suffice. However, it grants narrow exceptions to protect non-party personally identifiable information and, in extremely limited circumstances, source code. The court directs the parties to publicly re-file denied documents by April 4, 2025.
Topics
Practice areas
Questions Presented
- Whether the parties have met the burden of showing compelling reasons to seal entire documents filed in connection with summary‑judgment motions.
- Whether the parties have met the lesser "good cause" standard to seal documents filed in connection with sanctions motions.
Holdings
- Motions to seal entire documents are denied unless the movant demonstrates compelling reasons; only narrowly redacted portions may be sealed.
- The "good cause" standard is less stringent than the "compelling reasons" standard, but motions to seal entire documents still must be narrowly tailored; many such motions were denied.
Key quotations
“There is a general principle in favor of public access to federal court records. Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 602 (1978).”
“The proponent of sealing bears the burden with respect to sealing. A failure to meet that burden means that the default posture of public access prevails.”
Factual background
Plaintiffs and defendants each filed omnibus motions to seal large numbers of documents—including exhibits and declarations—submitted in connection with their respective summary‑judgment and sanctions motions. The parties argued that the documents contained confidential or commercially sensitive information, while the court noted the public‑access presumption and the burden on a movant to show compelling reasons for sealing.
Procedural history
The district court received separate omnibus motions to seal from plaintiffs and defendants seeking to seal numerous documents related to pending summary‑judgment and sanctions motions. The court previously denied earlier sealing requests and directed the parties to file a single, narrowed omnibus motion.
Remand instructions
The parties are directed to re‑file the documents for which sealing was denied on the public docket by April 4, 2025, and to conform future filings to this sealing order.