Shoals Technologies Group, LLC v. Voltage, LLC, and Ningbo Voltage Smart Production Co.

Summary

The United States District Court for the Middle District of North Carolina addresses motions to seal materials filed in connection with trial exhibits, a preliminary-injunction reply, a motion to reopen fact discovery, and a claim-construction motion. The court grants the motions concerning confidential financial, corporate, and technical information, grants the trial-transcript motion in part, and denies the motion concerning materials supporting the motion to reopen discovery. The court also directs the unsealing of specified discovery-related filings.

Holdings

1. The common-law right of access applies to judicial records but may be rebutted when countervailing interests heavily outweigh the public interest in access. The First Amendment right of access is narrower and applies only to particular judicial records and documents.
2. Documents filed in support of a purely procedural motion, such as a motion to reopen fact discovery, are not judicial records for purposes of the public right of access; a showing of good cause under Federal Rule of Civil Procedure 26(c) is sufficient to seal such materials.
3. The motion to seal docket entry 422 was granted in part and denied in part. The court permitted sealing of the trial-transcript excerpts but denied sealing of the memorandum because the proposed redactions did not involve confidential or sensitive information.
4. The motion to seal docket entry 425 was granted, including the proposed redactions to docket entry 427 and the sealing of exhibits 427-1 through 427-4.
5. The motion to seal docket entry 432 was granted, including docket entries 433 and 433-1, because the materials contained proprietary technical design information and were judicial records subject to at least the common-law access standard.

Questions Presented

1. Whether the materials submitted with the various motions were judicial records subject to the common-law or First Amendment right of public access.
2. What standard governed the motions to seal, including whether good cause under Federal Rule of Civil Procedure 26(c) sufficed for materials filed in support of purely procedural motions.
3. Whether the parties established a sufficient interest in confidentiality and showed that sealing or redaction was narrowly tailored and that less restrictive alternatives were inadequate.
4. Whether the court should grant, deny, or partially grant the motions to seal docket entries 422, 425, 430, and 432.

Disposition

other