Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation

Background

NVIDIA filed an administrative motion asking to seal the entirety of Exhibit A to its opposition to Valeo’s motion for a letter of request under the Hague Convention. Exhibit A consisted of NVIDIA’s responses to Valeo’s Interrogatory No. 2.

NVIDIA argued that the exhibit contained information about the organization of its source code, at least two specific source-code functions, certain NVIDIA employees, and the projects on which those employees worked.

Legal standard

The court explained that judicial records connected to dispositive motions generally receive a strong presumption of public access. For materials connected to motions only tangentially related to the merits, however, a party seeking to seal information must show “good cause” under Federal Rule of Civil Procedure 26(c). The court applied the good-cause standard here.

Ruling

The court held that NVIDIA had not shown good cause to seal the entire exhibit. The exhibit included objections to the interrogatories and high-level descriptions of NVIDIA’s technology and its employees’ work that did not reveal nonpublic information. The court also noted that the names of Mohammad Moniruzzaman and Mohamed Shawki Elamir, which appeared on page 11, had already been publicly disclosed.

The court found good cause to seal the names and responsibilities of NVIDIA employees whose work was not at issue in the motion, located on page 9, lines 4–15, and specific information describing NVIDIA’s work on technology improvements that had not yet been disclosed, located on page 11, lines 12–14. It found no other basis to seal the remainder of Exhibit A.

The court granted in part and denied in part NVIDIA’s request to seal documents. It ordered NVIDIA to file a public redacted version of Exhibit A consistent with the order no later than January 24, 2025.