RoadRunner Recycling, Inc. v. Recycle Track Systems, Inc.

Background

The order addressed motions to seal and supporting declarations connected to recent discovery disputes. RoadRunner Recycling, Inc. filed a September 5, 2024, discovery letter alleging spoliation, meaning the loss or destruction of potentially relevant evidence. RoadRunner moved to seal material from the defendants, Recycle Track Systems, Inc. and RecycleSmart Solutions, Inc. The defendants also moved to seal material in their response.

The defendants later filed a September 6, 2024, discovery letter seeking additional time for a deposition and moved to seal RoadRunner’s material. RoadRunner responded and separately moved to seal material in its response.

Legal standard

The court stated that the public has a right to know what materials courts use and whether courts provide relief. Filings more than tangentially related to the merits of a case may be sealed only for compelling reasons. Parties must provide a specific, factual basis for sealing and tailor proposed redactions to that basis. The court also stated that a protective order does not guarantee confidentiality when materials are filed with the court.

Rulings on the motions

For RoadRunner’s motion concerning the spoliation discovery letter, the court denied the proposed redaction of material paraphrasing testimony about the defendants’ Pello technology because the information had been disclosed elsewhere. The court also denied RoadRunner’s request to seal the entirety of excerpts from Yahya Laraki’s deposition. It found the proposed redactions overbroad and covering material related to the discovery dispute, including information that had been discussed in court.

For the defendants’ motion concerning their response to RoadRunner’s spoliation letter, the court denied the proposed redactions because they obscured general descriptions of the parties’ contentions, were supported only by a boilerplate explanation, and were not specifically supported by the declaration. The court also denied the request to seal the entirety of excerpts from Yahya Laraki’s deposition. It found that the excerpts gave only a general account of the defendants’ alleged technology development and noted that the subject had been discussed in court.

The court denied the defendants’ motion to seal RoadRunner’s material in the defendants’ deposition discovery letter. The order noted that RoadRunner’s filing concerning that motion declined to support redactions.

For RoadRunner’s motion concerning its response to the deposition letter, the court denied the proposed redactions to an email describing a two-and-a-half-year-old operating plan. RoadRunner’s general references to product-specific financial accounting, business strategy, and financial strategy did not provide the specific factual basis required for sealing. The court also denied RoadRunner’s request to seal the entirety of excerpts from a Gates deposition. It found that request facially unreasonable and stated that the court would not review the excerpts line by line to identify material that RoadRunner had not specifically identified as sealable.

Disposition

The court denied the motions to seal at Docket Nos. 95, 98, 101, and 105. It ordered all related filings to be re-filed publicly and without redactions by September 20, 2024. The court also stated that it awaited any omnibus sealing motion from RoadRunner concerning earlier filings.