Nielsen Consumer LLC v. Circana Group, L.P.
- James Oetken
- 1:22-cv-03235
- U.S. District Court · Southern District of New York
- 2
Nielson Consumer LLC v. Circana Group, L.P.: Judge Parker granted the parties’ motion to seal materials containing nonpublic business information and trade secrets.
Nielson Consumer LLC and Circana Group, L.P., whose discovery-related filings and exhibits were sealed or redacted.
What happened
In Nielson Consumer LLC v. Circana Group, L.P., the parties asked to redact their joint status update and seal or redact attached exhibits because they contained nonpublic business information and trade secrets.
The court found that the proposed redactions were narrowly tailored to protect competitive business information and granted the parties’ joint motion to seal. The court also directed the Clerk to terminate the motion.
Judge Katharine H. Parker cautioned that information sealed for this discovery dispute might not receive the same treatment with a later motion deciding the case, and advised the parties to limit documents they seek to seal.
The detailed version
- Nielsen Consumer LLC v. Circana Group, L.P. · No. 1:22-cv-03235
- James Oetken
- Nov. 21, 2024
Background
The parties filed a joint motion asking the court to redact their November 15, 2024 Joint Status Update Letter. They also asked to file Exhibits A through D under seal and Exhibits E, F, and G in redacted form. They said the requested protections covered references to nonpublic, commercially sensitive business information and trade secrets.
Court’s analysis
The court reviewed the parties’ filings and found that the proposed redactions were narrowly tailored to protect competitive business information. The court stated that the request was consistent with the standard from Lugosch v. Pyramid Co. of Onondaga, under which sealing must be supported by specific findings showing that it is essential to protect a higher-value interest and is narrowly tailored to that interest.
Ruling
The court granted the parties’ Joint Letter Motion to Seal. It cautioned that documents and information sealed in connection with this discovery dispute might not be treated the same way if submitted with a motion deciding the case. The court also advised the parties to consider whether particular documents needed to be attached to a discovery filing and whether they could reduce the materials they sought to seal. The Clerk was directed to terminate the motion at ECF No. 402.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.