Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation
- Virginia Demarchi
- 5:23-cv-05721
- U.S. District Court · Northern District of California
- 3
In Valeo v. NVIDIA, Judge DeMarchi ordered narrow redactions of NVIDIA’s confidential information in discovery filings.
Valeo Schalter und Sensoren GmbH, NVIDIA Corporation, and members of the public seeking access to the identified court filings and exhibits.
What happened
In Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation, Valeo filed four motions asking the court to seal materials connected to discovery-dispute letters and attachments. NVIDIA supported the requests but said a narrower set of materials needed sealing.
The court applied a lower standard requiring a specific showing of good cause because the discovery disputes were only indirectly related to the case’s merits. NVIDIA identified confidential business information and technical and personnel details about ongoing and future projects, and the court found that disclosure could harm NVIDIA’s competitive position and increase security risks.
Judge Virginia K. DeMarchi ordered the identified portions of the discovery filings and exhibits sealed, including one exhibit sealed in its entirety. The court found the redactions minimal and appropriately limited; redacted public versions were available, and it required no further action from the parties.
The detailed version
- Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation · No. 5:23-cv-05721
- Virginia Demarchi
- Jan. 9, 2025
Background
On December 26, 2024, Valeo filed four administrative motions concerning whether materials submitted by NVIDIA should be sealed in connection with four discovery-dispute letters and their attachments. NVIDIA filed a supporting declaration but stated that fewer materials required sealing than Valeo had proposed.
Legal standard
The court explained that judicial records and documents accompanying motions that would resolve claims generally receive a strong presumption of public access. That presumption is weaker for motions only indirectly related to the merits, such as the discovery disputes at issue here. For those materials, the party seeking protection must show good cause under Federal Rule of Civil Procedure 26(c).
Court’s ruling
The court found good cause to seal the information NVIDIA designated. NVIDIA identified confidential business information and specific technical and personnel details concerning ongoing and future projects. NVIDIA stated that disclosure could damage its competitive position and increase the risk that bad actors could obtain its confidential technical information. The court found that the proposed redactions were minimal and narrowly tailored.
The court ordered the following materials sealed as specified in NVIDIA’s exhibits to Michael LaFond’s declaration:
- Portions of the discovery letter brief concerning production of custodial electronically stored information, identified as Dkt. No. 169. - Portions of the discovery letter brief concerning NVIDIA’s alleged failure to produce responsive documents, identified as Dkt. No. 171, and portions of Exhibits 3 and 4 to that filing. - Portions of the discovery letter brief concerning production of financial documents, identified as Dkt. No. 172, and all of Exhibit 2 to that filing. - Portions of the discovery letter brief concerning NVIDIA’s preparation of witnesses under Federal Rule of Civil Procedure 30(b)(6), identified as Dkt. No. 173, and portions of Exhibits 2, 3, and 4 to that filing.
The court noted that redacted versions were available on the public docket and stated that no further action by the parties was required.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.