Locus Technologies v. Honeywell International Inc.

Background

Locus sued Honeywell in a diversity action, asserting breach-of-contract, account-stated, and misappropriation-of-trade-secrets claims. The claims arose from a sixteen-year contractual relationship during which Honeywell used Locus’s proprietary software products. Locus alleged that Honeywell breached the contracts, failed to make required payments, and disclosed Locus’s proprietary information in a 2018 request for proposal.

Honeywell had moved for summary judgment. In connection with that motion, the parties sought to seal parts of the summary-judgment record. In an earlier order, the court granted in part and denied in part the parties’ sealing motions and allowed Locus to file a new motion addressing certain documents. Locus then moved to seal portions of the expert report of Zaydoon Jawadi and portions of the declaration of Rakesh Singh.

Legal standard

The court explained that documents filed in support of a motion generally are “judicial documents”—records relevant to the court’s work and useful in the judicial process. Such documents carry a presumption of public access, and the presumption was strong here because the materials were submitted in support of a summary-judgment motion and could directly affect the court’s decision.

To overcome that presumption, Locus had to provide specific facts showing that sealing was necessary to protect a higher value and that the requested sealing was narrowly tailored. The court applied the Second Circuit’s three-step approach: determine whether the material is a judicial document, assess the strength of the public-access presumption, and balance that presumption against competing interests such as privacy or protection of confidential information.

Rulings

For the Jawadi Report, the court granted some proposed redactions because the information revealed Locus’s alleged trade secrets. It denied other proposed redactions because the material did not contain trade-secret, confidential, or proprietary information. For several portions, the court granted in part and denied in part the request: it approved specified paragraphs containing alleged trade secrets but denied redaction of the remaining paragraphs.

For the Singh Declaration, the court granted the motion as to each proposed redaction because the information revealed Locus’s alleged trade secrets.

Disposition

The court granted in part and denied in part Locus’s motion to seal as set out in the order. It directed the parties to make the necessary public-docket filings by January 9, 2025, and directed the Clerk of Court to terminate the motion. This order did not decide the merits of Locus’s contract, account-stated, or trade-secrets claims.