Laatz v. Zazzle, Inc.
- Beth Freeman
- 5:22-cv-04844
- U.S. District Court · Northern District of California
- 4
In Laatz v. Zazzle, Inc., Judge Freeman granted Defendants’ motion to seal exhibits containing confidential business and personal information.
The ruling affects Defendants, including Zazzle, by allowing specified exhibits and portions of exhibits to remain sealed, and limits public access to those materials.
What happened
In Laatz v. Zazzle, Inc., Defendants asked to seal Exhibits B and C attached to their opposition to Plaintiff’s request for relief from a magistrate judge’s nondispositive pretrial order. The exhibits had been designated confidential under a protective order.
The court applied the lower “good cause” standard because the exhibits were connected to a nondispositive discovery motion. It found that the exhibits contained information about Zazzle’s business structure, strategies, practices, and analyses, as well as personal information, and that disclosure could harm Zazzle’s competitive position.
Judge Beth Freeman granted Defendants’ administrative motion to file under seal. The ruling allowed all of Exhibit B to be sealed and allowed specified highlighted portions of Exhibit C to be sealed.
The detailed version
- Laatz v. Zazzle, Inc. · No. 5:22-cv-04844
- Beth Freeman
- Sept. 25, 2024
Background
Defendants filed an administrative motion to seal Exhibits B and C to the declaration of Thomas Nolan. The exhibits were attached to Defendants’ opposition to Plaintiff’s motion for relief from a magistrate judge’s nondispositive pretrial order. Zazzle had designated the exhibits as confidential under the case’s protective order.
Defendants filed the sealing request in two docket entries. One contained the motion and supporting papers; the other contained the opposition and the exhibits under seal. The opinion notes that Defendants referred to three exhibits on two pages of the motion, but the motion, supporting declaration, and proposed order discussed only Exhibits B and C.
Legal standard
The court explained that judicial records generally carry a presumption of public access. Records attached to motions that are unrelated or only tangentially related to the merits of a case, however, may be sealed under the lower “good cause” standard in Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing of specific harm or prejudice if the information is disclosed. The court also required compliance with Civil Local Rule 79-5, including an explanation of the interests supporting sealing, the injury from disclosure, and why a less restrictive alternative would not suffice.
Court’s analysis
The court found that the good-cause standard applied because the materials were related to a nondispositive pretrial discovery motion. It found good cause to seal Exhibits B and C because they contained information concerning Zazzle’s business structure, strategies, practices, and analyses. The court determined that public disclosure of this information would harm Zazzle’s competitive standing.
The court also found good cause to seal personal information contained in Exhibit C. It further found that the proposed redactions were narrowly tailored to seal only material that could properly be sealed.
Ruling
Judge Beth Freeman granted Defendants’ Administrative Motion to File Under Seal. The order permitted the entirety of Exhibit B, identified as ZAZZLE-003068, to be filed under seal. It permitted the highlighted sections on pages 10 and 92–93 of Exhibit C, an excerpt of Catherine Sheu’s deposition transcript, to be filed under seal. The order resolved docket entries 280 and 281.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.