NetJets Sales, Inc., et al. v. Colin Fan

Fan · United States District Court for the Southern District of Ohio · December 5, 2025 · No. 2:25-cv-01361

Summary

The United States District Court for the Southern District of Ohio denied Plaintiffs’ motion to seal portions of their complaint and two attached exhibits in a breach-of-contract action involving NetJets and Colin Fan. The court held that Plaintiffs failed to show a compelling interest favoring nondisclosure, failed to overcome the public’s interest in access to judicial records, and failed to propose narrowly tailored redactions. Plaintiffs were ordered to file an unredacted complaint and exhibits within seven days.

Court
United States District Court for the Southern District of Ohio
Jurisdiction
United States District Court for the Southern District of Ohio
Decision date
December 5, 2025
Docket number
2:25-cv-01361
Disposition
other

Questions Presented

  1. Whether Plaintiffs established a compelling interest sufficient to overcome the strong presumption of public access to judicial records.
  2. Whether the proposed sealing and redactions were narrowly tailored to protect any legitimate confidentiality interest.
  3. Whether a contractual confidentiality provision, competitive-interest assertions, pricing information, and payment information justified sealing the Complaint and its exhibits.

Holdings

  1. Plaintiffs failed to demonstrate a compelling interest sufficient to overcome the strong presumption of public access because generalized assertions of competitive harm and confidentiality were insufficient.
  2. The proposed sealing and redactions were not narrowly tailored because Plaintiffs sought to seal entire exhibits and extensive portions of the Complaint without explaining, document by document and line by line, why particular information required secrecy.
  3. A confidentiality agreement between the parties does not, by itself, justify sealing information filed in a federal court proceeding.

Court Document

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