Chadly v. Music Together, LLC

Background

Music Together, LLC, a defendant, moved to seal portions of an attachment to its motions to transfer the case and dismiss the claims. Those underlying motions had since been withdrawn. The attachment was a purported employment agreement between Music Together and third party Thomas Foote. The requested redactions covered provisions concerning intellectual-property assignment rights, confidentiality, and disclosure.

Legal standard

The court explained that court records are generally open to the public. Materials more than tangentially related to the merits of a case may be sealed only for “compelling reasons.” A party seeking to seal records must narrowly tailor the request, identify each document or passage to be sealed, explain the interests supporting secrecy and the harm from disclosure, and show why less restrictive alternatives would not work. General or unsupported claims of possible harm are insufficient.

Court’s reasoning

The court first found that the motion failed procedurally. Music Together filed the motion containing the redacted attachment on April 29, but filed the motion to seal on May 7. The court stated that the district’s rules require a sealing motion to be filed at the same time as the document.

The court also found that the proposed redactions failed substantively. Music Together acknowledged that the agreement’s intellectual-property provisions had to be disclosed because they allegedly concerned the works disputed in the case, but it did not provide specific facts explaining why some subsections should be disclosed while others should be sealed. The court therefore found the request overbroad.

The court likewise found the proposed redactions to the confidentiality and disclosure section overbroad. They included legal boilerplate allowing disclosure under a valid court order. Music Together argued that disclosure could harm Foote and asserted that the company could face competitive harm. The court found those explanations insufficiently specific and held that Music Together had not overcome the public’s strong presumptive right of access. The court also stated that the agreement’s treatment of employees and licensees, including the purported co-author of the disputed works, was more than tangentially related to the case.

Disposition

The court denied the administrative motion to seal. It ordered Music Together to refile the attachment, identified as Dkt. Nos. 14-9 and 16-3, in compliance with the order by September 5, 2024.