Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation
- Virginia Demarchi
- 5:23-cv-05721
- U.S. District Court · Northern District of California
- 2
In Valeo v. NVIDIA, Judge DeMarchi granted NVIDIA’s request to file interrogatory responses and ordered limited sealing of confidential portions.
Valeo and NVIDIA were affected by the filing and sealing rulings; public access was preserved through a redacted version filed on the docket.
What happened
In Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation, NVIDIA asked to file Valeo’s responses to Interrogatories 6 and 7 in support of a pending discovery dispute. Valeo said it did not believe the material was relevant but did not oppose the court’s review.
NVIDIA and Valeo also sought to seal portions of the responses. NVIDIA identified confidential names of files and functions in its proprietary source code, while Valeo identified confidential technical information and source-code folder structures. Both parties said public disclosure could cause competitive harm.
Judge Virginia K. DeMarchi granted NVIDIA’s request for leave to file the responses and ordered the designated portions sealed. The court found good cause under the discovery-sealing standard and said the redactions were minimal and narrowly tailored; a redacted public version was already available.
The detailed version
- Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation · No. 5:23-cv-05721
- Virginia Demarchi
- Aug. 16, 2024
Background
NVIDIA filed an administrative motion seeking leave to file Valeo’s responses to NVIDIA’s Interrogatory Nos. 6 and 7 in support of a pending discovery dispute. Valeo stated that it did not believe the material was relevant but did not object to the court reviewing it as referenced in NVIDIA’s letter brief.
NVIDIA also filed two motions to seal portions of the interrogatory responses. Valeo filed a statement supporting those motions and identified the portions it sought to have sealed.
Sealing Standard
The court explained that judicial records accompanying dispositive motions generally may be sealed only for compelling reasons supported by specific factual findings. But that heightened standard does not apply equally to discovery matters that are only tangentially related to the merits. Because the discovery matters here did not address the merits of either party’s claims or defenses, the court applied the lower “good cause” standard under Federal Rule of Civil Procedure 26(c).
NVIDIA said the information it sought to seal concerned confidential names of files and functions in its proprietary source code and that disclosure could create a competitive disadvantage. Valeo said the portions it sought to seal included pictures of highly confidential, proprietary, and competitive technical information, as well as the structures and names of folders comprising its trade-secret source code. Valeo asserted that disclosure would cause competitive harm.
Ruling
The court granted NVIDIA’s motion for leave to file Valeo’s responses. It also found good cause to seal the designated portions of the interrogatory responses. The court ordered sealed the portions highlighted in yellow in Valeo’s Second Supplemental Objections and Responses to NVIDIA’s First Set of Interrogatories, Nos. 6 and 7, and the portions of pictures redacted on pages 10, 11, and 12. The court found that the redactions were minimal and narrowly tailored. Because a redacted version was already available on the public docket, it required no further action.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.