Laatz v. Zazzle, Inc.

Summary

The United States District Court for the Northern District of California grants Plaintiff Nicky Laatz’s administrative motion to consider whether materials submitted in support of a motion to exclude expert testimony should be sealed. Applying the compelling-reasons standard, the court permits redaction or sealing of confidential information concerning Zazzle’s proprietary Design Tool, users, designs, sales, revenues, and expenses.

Holdings

1. Because the sealing motion concerned materials submitted in support of a motion to exclude expert testimony, the materials were more than tangentially related to the underlying cause of action, and the court applied the compelling-reasons standard.
2. The court held that Defendants established compelling reasons to seal information revealing Zazzle's confidential internal technical operations and commercially sensitive information, and that the requests were narrowly tailored because no less restrictive alternative was sufficient.

Questions Presented

1. Whether the portions of expert reports submitted in support of Plaintiff's motion to exclude defendants' experts should be sealed under the compelling-reasons standard.
2. Whether Defendants' proposed sealing requests were narrowly tailored and supported by specific facts showing that disclosure would cause competitive or commercial harm.

Disposition

other