Summary
The United States District Court for the District of Delaware denied without prejudice Defendants’ unopposed motion to redact portions of the Court’s November 18, 2025 Memorandum Opinion in a patent infringement dispute. The Court held that Defendants had not articulated sufficiently specific harm to overcome the common-law and First Amendment rights of access to judicial records and summary judgment materials. The Court permitted Defendants to renew their motion by January 30, 2026 and ordered that the Memorandum Opinion remain under seal pending further action.
Holdings
- The memorandum opinion is a judicial record subject to the common-law right of public access, and Defendants failed to rebut the resulting strong presumption of access.
- Summary-judgment records implicate the First Amendment right of public access.
- Defendants failed to overcome the First Amendment presumption of access because they did not show with sufficient specificity that disclosure would cause a clearly defined and serious injury.
Questions Presented
- Whether portions of the Court's November 18, 2025 memorandum opinion could be redacted under the common-law right of public access to judicial records.
- Whether summary-judgment records implicate the First Amendment right of public access in the Third Circuit.
- Whether Defendants identified a sufficiently specific and serious injury to overcome the common-law and First Amendment presumptions of access.
Disposition
other
Cases Cited (13)
- In re Avandia Mktg., Sales Pracs. & Prods. Liab. Litig., 924 F.3d 662 (3d Cir. 2019)(followed)
- Publicker Indus., Inc. v. Cohen, 733 F.2d 1059 (3d Cir. 1984)(followed)
- Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir. 1994)(followed)
- Glenmede Tr. Co. v. Thompson, 56 F.3d 476 (3d Cir. 1995)(followed)
- Goldstein v. Forbes (In re Cendant Corp.), 260 F.3d 183 (3d Cir. 2001)(followed)
- Republic of the Philippines v. Westinghouse Elec. Corp., 949 F.2d 653 (3d Cir. 1991)(followed)
- Lipocine Inc. v. Clarus Therapeutics, Inc., 2020 WL 4569473 (D. Del. Aug. 7, 2020)(followed)
- Littlejohn v. Bic Corp., 851 F.2d 673 (3d Cir. 1988)(followed)
- Miller v. Indiana Hosp., 16 F.3d 549 (3d Cir. 1994)(followed)
- N. Jersey Media Grp. Inc. v. United States, 836 F.3d 421 (3d Cir. 2016)(followed)
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Cited In (0)
No citing cases on record yet.