X Corp. v. Bright Data Ltd.
- William Alsup
- 3:23-cv-03698
- U.S. District Court · Northern District of California
- 8
In X Corp. v. Bright Data, Judge Alsup denied all five motions to seal because the parties did not adequately support the proposed redactions.
X Corp. and Bright Data Ltd. must refile documents conforming with the order by January 24, 2025; the proposed redactions covered by the denied motions were subject to public disclosure.
What happened
X Corp. v. Bright Data Ltd. involved five requests to keep portions of court filings from public view. The requests concerned X Corp.’s proposed second amended complaints and Bright Data Ltd.’s answer and counterclaim.
The court said filings connected to the substance of a case may be sealed only for compelling reasons, and other filings require good cause. It found that X Corp. failed to support its proposed redactions, used broad and general explanations, and sought to hide information it had disclosed elsewhere. X Corp. also failed to file required supporting statements for material that Bright Data sought to seal.
Judge William Alsup denied all five motions to seal—Docket Nos. 89, 117, 120, 128, and 157—and ordered the parties to refile documents consistent with the order by January 24, 2025.
The detailed version
- X Corp. v. Bright Data Ltd. · No. 3:23-cv-03698
- William Alsup
- Jan. 12, 2025
Background
The order resolved all pending administrative motions to seal related to X Corp.’s second amended complaint and Bright Data Ltd.’s answer and counterclaim. X Corp. filed motions to seal its material connected to its first and second requests for leave to file a second amended complaint, including its opening and reply briefs, proposed complaint, exhibits, and redline. Bright Data filed motions to seal X Corp.’s material in Bright Data’s opposition and answer and counterclaim.
Legal standard
The court explained that the public has a right to know what relief public courts provide. Court filings more than tangentially related to the merits may be sealed only for “compelling reasons,” while filings unrelated to the merits may be sealed for “good cause.” A party seeking to seal material must identify each proposed redaction, explain the legitimate interest supporting it, describe the injury that disclosure would cause, and explain why fewer redactions would not be sufficient. The supporting assertions must be supported by a statement or declaration.
The court recognized that sealing may sometimes protect trade secrets or business information whose disclosure could harm a party’s competitive position. But it rejected vague, general claims of possible harm and stated that a protective order or confidentiality designation alone is not enough.
Rulings on the motions
The court denied Bright Data’s motion to seal X Corp.’s material in Bright Data’s opposition, Docket No. 120. X Corp. did not file the supporting statement required by the local rule within seven days. Because of that failure, the proposed redactions became subject to disclosure.
The court denied X Corp.’s motion concerning its first motion for leave to amend, Docket No. 89. It found the proposed redactions overbroad, supported by boilerplate explanations, and inconsistent with information X Corp. had published elsewhere. The court also found that some proposed redactions covered generic information, including a statement that scraping can degrade user experiences, without a sufficient showing of harm.
The court denied X Corp.’s motion concerning its second motion for leave to amend, including the opening brief, proposed complaint with exhibits, and redline, Docket No. 117. The court found that X Corp. again sought to redact information disclosed elsewhere, relied on common general explanations for different redactions, and failed to provide specific facts allowing the court to distinguish between information that might warrant sealing and information that would not.
The court denied X Corp.’s motion concerning its reply brief, Docket No. 128, because the proposed redactions had already been rejected for the same reasons.
The court denied Bright Data’s motion to seal X Corp.’s material in Bright Data’s answer and counterclaim, Docket No. 157. X Corp. again failed to file the required supporting statement, and the court found no reason why redactions rejected in the complaint would become justified merely because the material was quoted in the answer.
Disposition
The court denied all five pending administrative motions to seal: Docket Nos. 89, 117, 120, 128, and 157. The parties were ordered to refile documents conforming with the order by January 24, 2025.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.