Laatz v. Zazzle, Inc.

Background

The court considered two administrative sealing motions together. Nicky Laatz asked the court to decide whether materials that Zazzle had designated confidential should be sealed. The materials were filed with Laatz’s renewed motion for relief from the scheduling order. Zazzle filed a statement supporting sealing and its own motion to seal. Laatz filed no response to those submissions.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. But records connected to motions that are not related, or are only tangentially related, to the merits of a case are subject to the lower “good cause” standard. That standard requires a specific showing of likely harm from disclosure. The court also required compliance with the Northern District of California’s local sealing rule, including narrowly tailored redactions and supporting reasons or evidence when necessary.

Because the materials concerned a motion for relief from the scheduling order, the court applied the good-cause standard.

Rulings on the materials

For the redacted portions of Laatz’s renewed motion for relief from the scheduling order, the court:

- Granted sealing for portions on pages 4 and 6 within Section III.B and lines 1–2 on page 5. The court found that these portions contained confidential information about Zazzle’s electronic systems, electronic storage and backup practices, and revenues, and that public disclosure could harm Zazzle’s competitive position. - Denied sealing for highlighted portions on pages 2–4 within Sections I–III.A because Zazzle did not seek to keep those portions sealed. - Denied sealing for lines 3–4 on page 5 and the highlighted portion on page 7 because those portions did not contain confidential competitive information.

For the deposition exhibits, the court denied sealing the entire Jason Kang deposition transcript because Zazzle did not seek to maintain that document under seal. The court granted sealing for the highlighted portion on page 8 of the Richard Hottelet deposition transcript because it contained Hottelet’s personal address. The court denied sealing for the remainder of that transcript because Zazzle did not seek to keep the entire document sealed.

Disposition

The court granted in part and denied in part Laatz’s Administrative Motion to Consider Whether Defendants’ Materials Should Be Sealed, ECF No. 267. It also granted in part and denied in part Zazzle’s Administrative Motion to File Under Seal, ECF No. 278. The court ordered Laatz to file an unredacted version of Exhibit 3 on the public docket within seven days. It also ordered her to file versions of the renewed motion for relief from the scheduling order and Exhibit 4 with redactions adjusted to match the ruling within seven days. Judge Beth Labson Freeman signed the order.