Valve Corporation v. Rothschild et al.

Summary

The United States District Court for the Western District of Washington granted in part Defendants’ motion to seal expert reports filed in support of Daubert motions. The Court held that the compelling-reasons standard applied and permitted limited redactions to the Schenk and Al-Salam reports based on confidential financial and litigation-related information. The Court denied sealing of the Gugliuzza report because Defendants failed to demonstrate the required interests, injury, and need for sealing rather than redaction.

Holdings

1. The compelling-reasons standard applies because the expert reports are related to the claims, defenses, and damages at issue and the Daubert motions are more than tangentially related to the merits.
2. Valve established compelling reasons for limited redactions to the Schenk and Al-Salam reports.
3. Defendants failed to meet their burden to keep the Gugliuzza report under seal, and the report must be unsealed.

Questions Presented

1. What standard governs a motion to seal expert reports filed in connection with Daubert motions related to the claims, defenses, and damages in the case?
2. Whether Valve established compelling reasons for limited redactions to the Schenk and Al-Salam expert reports.
3. Whether Defendants established the required interests, injury, and need for complete sealing of the Gugliuzza expert report.

Disposition

other