Nautilus Biotechnology, Inc. v. Somalogic, Inc.

Background

The court considered two administrative motions filed by Nautilus Biotechnology, Inc.: a motion to seal portions of its First Amended Complaint and a motion asking the court to consider whether material belonging to another party should be sealed. Somalogic, Inc., and the California Institute of Technology did not oppose either motion. The defendants also filed a declaration supporting the second motion.

The material involved two categories of information. The first consisted of about seven lines of text and a figure describing technical details, including the configuration of key components, of Nautilus’s unreleased platform. Nautilus stated that public disclosure could cause competitive harm. The second consisted of about 25 lines concerning the defendants’ licensing agreements with an unnamed non-party competitor. The defendants stated that these passages contained confidential business and financial terms and could disadvantage the defendants and the competitor in future licensing discussions.

Legal Standard

The court explained that judicial records generally carry a strong presumption of public access. For records more than tangentially related to the underlying claims, a party seeking a seal must show compelling reasons supported by specific facts that outweigh the public’s interest in disclosure. The court also stated that requests must be narrowly tailored and that a protective order or broad confidentiality designation alone is not enough to justify sealing.

Ruling

The court found compelling reasons to seal information that would reveal details of Nautilus’s unreleased platform and confidential business and financial terms in the licensing agreements. It also found that the requests were narrowly tailored and that no less restrictive alternative would adequately protect the information.

Judge Beth Labson Freeman granted the sealing requests as follows:

- The highlighted portions on page 14, lines 6–18, of the First Amended Complaint were granted sealing because they reflected specific technical details of Nautilus’s unreleased platform. - The highlighted portions on page 2, lines 8–9; page 3, lines 9–16, 18–19, and 21–26; page 6, lines 1–3; page 12, lines 17–19; and page 13, line 10, were granted sealing because they contained confidential business information about the defendants’ license agreements.

The order granted the sealing requests regarding the specified portions; it did not seal the entire First Amended Complaint or resolve the underlying claims.