Laatz v. Zazzle, Inc.

Summary

The Northern District of California partially granted and partially denied Defendants’ administrative motion to seal materials filed in connection with a Daubert motion. The Court denied sealing for information previously publicly disclosed or not sought to be sealed by Plaintiff, but granted sealing for narrowly tailored confidential business information concerning Zazzle’s operations, users, products, sales, revenues, expenses, and damages calculations.

Holdings

1. Because the sealing motion concerned Defendants' motion to exclude testimony of Plaintiff's designated expert witness, the court applied the compelling-reasons standard rather than the lower good-cause standard.
2. Defendants established compelling reasons to seal narrowly tailored portions containing confidential information about Zazzle's proprietary Design Tool, designers, designs, products, users, sales, revenues, expenses, and related damages calculations.
3. The court denied sealing for materials that had been previously publicly disclosed on the docket and for materials that Plaintiff expressly did not seek to seal.

Questions Presented

1. What standard governs Defendants' request to seal portions of materials submitted with their Daubert motion?
2. Whether Defendants established compelling reasons to seal the requested redactions and exhibits under the governing standard and Civil Local Rule 79-5.
3. Whether materials should be denied sealing because the information was previously publicly disclosed or Plaintiff did not request sealing.

Disposition

other