Locus Technologies v. Honeywell International Inc.

Background

Locus Technologies asserts breach-of-contract, account-stated, and trade-secret-misappropriation claims against Honeywell International Inc. The dispute arises from a sixteen-year contractual relationship involving Locus’s proprietary software products. Honeywell had moved for summary judgment, and both parties asked to seal parts of the summary-judgment record, including deposition testimony, expert reports, exhibits, financial information, business information, and settlement materials.

A sealing order restricts public access to specified court filings or portions of filings. The court explained that materials filed in support of summary judgment are “judicial documents” and therefore carry a strong presumption of public access. A party seeking sealing must provide specific facts showing that sealing is needed to protect a higher value and is narrowly tailored to that purpose.

Locus’s Requests

The court granted sealing for many materials containing detailed information about Locus’s alleged trade secrets, proprietary pricing, research and development expenditures, internal financial statements, competitive bidding practices, confidential settlement or mediation communications, and network-security measures. The court also sealed specified testimony about Locus’s software, pricing formulas, software architecture, process-flow diagrams, user roles and permissions, database information, and information in Honeywell’s request for proposal that Locus alleged disclosed its trade secrets.

The court also granted sealing for materials concerning Locus’s damages and financial projections when those materials were prepared for mediation, as well as medical information concerning Todd Pierce. It sealed certain Honeywell-related materials that contained confidential business information, including cost-savings data, vendor-selection strategy, and competitive analyses. It also sealed cost and pricing information belonging to the non-party Earthsoft because the privacy interests of non-parties can support sealing.

The court denied sealing for information that was already publicly available, including the statement of work and related pricing information attached to the publicly filed complaint. It also denied sealing for certain high-level descriptions of Locus’s software, information characterized as public-domain knowledge, internal accounting information for which Locus had not shown a risk of harm, and portions of an expert’s testimony that merely repeated information already disclosed in the complaint.

The court denied Locus’s request to seal the report of Honeywell’s expert, David Rich. The report identified categories of alleged trade secrets and discussed the conclusions of Locus’s expert, but did not disclose detailed descriptions of those alleged trade secrets beyond what was already in the complaint. The court also denied without prejudice Locus’s request to seal the report of its expert, Jay Jawadi, and accompanying exhibits. The court noted that Jawadi’s deposition was publicly available and discussed the report in detail, and directed Locus to support any renewed request with document-by-document explanations and narrowly tailored proposed redactions.

Honeywell’s Requests

The court granted sealing for Honeywell materials containing cost-savings data, vendor-selection strategy, competitive analyses, and other sensitive business information. It also granted sealing for documents containing Earthsoft’s cost and pricing information.

The court denied without prejudice Honeywell’s request to seal materials related to an internal investigation of a former employee’s performance. Honeywell had not explained the relevance of those materials or provided sufficient legal support for sealing them. The court allowed Honeywell to file a renewed motion explaining the materials’ relevance, proposing redactions, and showing why those redactions were necessary and narrowly tailored.

Disposition and Reasoning

The court concluded that the parties’ motions to seal were granted in part and denied in part as set forth in the order. The Clerk was directed to seal or unseal specified docket materials, and the parties were directed to make the required public-docket filings by December 20, 2024. The order addressed public access to the summary-judgment record; it did not decide Honeywell’s underlying summary-judgment motion or resolve Locus’s contract and trade-secret claims.