Laatz v. Zazzle, Inc.

Background

Nicky Laatz filed an administrative motion asking the court to consider whether materials submitted by Zazzle, Inc. should be sealed. The materials were connected to Laatz’s motion for relief from a magistrate judge’s nondispositive pretrial order. Zazzle supported sealing some of the materials and separately moved to file those materials under seal. Laatz did not respond to Zazzle’s statement or motion.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. But materials connected to motions that are not related, or are only indirectly related, to the merits of the case may be sealed under the lower “good cause” standard in Federal Rule of Civil Procedure 26(c). That standard requires a specific showing of the harm that disclosure would cause. The court also required compliance with the Northern District of California’s local sealing rule, including a narrowly tailored request and consideration of whether a less restrictive alternative would protect the information.

Because the materials concerned a motion for relief from a nondispositive pretrial order, the court applied the good-cause standard. The court found that Zazzle had shown sufficient grounds to seal information revealing confidential details about its database, electronic systems, internal procedures, customer and sales information, and business operations. The court also found that Zazzle’s requests were narrowly tailored and that no less restrictive alternative would adequately protect the information.

Rulings on the materials

The court ordered the following:

- The redacted portions of the motion for relief from the magistrate judge’s pretrial order were sealed because they contained confidential information about Zazzle’s electronic systems, storage practices, server usage, and revenues. This request was granted. - The highlighted excerpts from Jason Li’s deposition transcript were granted in part and denied in part. The court granted sealing for the specified red highlights at pages 13–15, 39–40, 87–89, 92–93, 162, 221–222, 233–234, and 254–255 because they concerned confidential information about Zazzle’s electronic systems, storage practices, reporting database, and Design Tool. The court denied sealing for the remaining yellow-highlighted portions because Zazzle did not seek to keep them sealed. - The entire document containing Zazzle’s July 3, 2024 amended responses and objections to Laatz’s interrogatories was sealed because it contained confidential information about Zazzle’s internal processes and data concerning its designers, customers, website visitors, and products. - The entire exhibit containing information about Zazzle’s number of designs, designers, products for sale, and sales volume was sealed. - The request concerning highlighted portions of excerpts from Jason Kang’s deposition transcript was denied because Zazzle did not request redaction of that material. - Specified portions of Daniel Garrie’s declaration were sealed because they contained confidential information derived from Jason Li’s deposition, including information about Zazzle’s electronic systems, storage practices, and Design Tool.

Disposition

The court granted in part and denied in part Laatz’s administrative motion to consider whether Zazzle’s materials should be sealed. It granted Zazzle’s administrative motion to file under seal. The court directed Zazzle to file a revised redacted version of the motion for relief and its supporting exhibits in the public record within seven days of the order.