Laatz v. Zazzle, Inc.

Background

Plaintiff Nicky Laatz filed an administrative motion asking the court to consider sealing materials submitted by Defendants Zazzle, Inc. and Mohamed Alkhatib. The materials were submitted in connection with Laatz’s objections to the defendants’ opposition to her motion for relief from a magistrate judge’s nondispositive pretrial order. The defendants filed a statement supporting sealing, and Laatz did not submit a response.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. But records connected to motions that are not, or are only tangentially, related to the merits of a case may be sealed under the lower “good cause” standard in Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing of specific harm from disclosure. The court also applied Northern District of California Civil Local Rule 79-5, which requires sealing requests to identify the interests supporting secrecy, the injury from disclosure, and why a less restrictive alternative would not suffice.

Court’s analysis

Because the materials concerned a motion for relief from a nondispositive pretrial order, the court applied the good-cause standard. The information at issue consisted of approximately fourteen lines in the Declaration of Daniel Garrie concerning Zazzle’s electronic systems, including its database and backup and storage practices. Zazzle characterized the information as confidential business information involving its practices and strategies and argued that public disclosure could create a competitive disadvantage.

The court found that the defendants had established sufficient reasons to protect the confidential information, including information that could reveal Zazzle’s business practices and strategies. It also found that the proposed redactions were narrowly tailored and that no less restrictive alternative would adequately protect the information.

Disposition

Judge Beth Labson Freeman granted the defendants’ requests to seal and ordered redactions to specified highlighted portions of ECF No. 313-2, the Declaration of Daniel Garrie concerning the Beaver Declaration, identified in the filing as ECF No. 312-2. The order did not decide the merits of the underlying dispute or Laatz’s motion concerning the magistrate judge’s pretrial order.