Laatz v. Zazzle, Inc.

Background

Defendants Zazzle, Inc. and Mohamed Alkhatib filed an administrative motion to seal materials submitted with their opposition to Plaintiff’s motion for relief from a magistrate judge’s nondispositive pretrial order. Nicky Laatz did not respond to the motion.

The materials included portions of Defendants’ opposition and supporting declarations, as well as excerpts from Jason Li’s deposition. Defendants sought to redact information about Zazzle’s design volumes; its database and electronic systems; its designs, designers, users, and products; and the technical operation of its Design Tool and electronic systems. Defendants argued that disclosure would harm Zazzle’s competitive position and that no less restrictive alternative would adequately protect the information.

Legal Standard and Analysis

The court explained that judicial records generally carry a strong presumption of public access. But records attached to motions that are not related, or are only tangentially related, to the merits are governed by the lower “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing of specific prejudice or harm from disclosure. The court also discussed the requirements of Civil Local Rule 79-5, including explaining the interests supporting sealing, the injury that would result from denial, why a less restrictive alternative would not suffice, and limiting sealing to the material that requires protection.

Because the underlying motion concerned relief from a nondispositive pretrial order and was only tangentially related to the merits, the court applied the good-cause standard. The court found that Defendants established sufficient reasons to seal confidential information about Zazzle’s database, proprietary electronic systems, design volumes, designs, designers, users, products, and Design Tool. The court stated that public disclosure of the information could harm Zazzle’s competitive position.

Order

The court granted the sealing requests for each of the following: the specified portions of Defendants’ opposition; the specified portions of the Beaver Declaration; the specified portions of the Nolan Declaration; and the specified excerpts from Jason Li’s deposition transcript. The court also directed Defendants to file a revised redacted version of the Amended Complaint in the public record within seven days of the order’s issuance.