Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation

Background

Valeo filed an administrative motion asking the court to consider whether NVIDIA’s material should be sealed. NVIDIA then filed a declaration supporting sealing under Local Rule 79-5(f)(3). The materials concerned a discovery dispute and did not address the merits of either party’s claims or defenses.

Legal standard

The court explained that judicial records connected to dispositive motions generally receive a strong presumption of public access, which can be overcome only by compelling reasons supported by specific factual findings. Because the discovery matters here were only tangentially related to the merits, the court applied the lower “good cause” standard under Federal Rule of Civil Procedure 26(c).

Ruling

The court found good cause to seal the information NVIDIA designated. NVIDIA said the information consisted of confidential business information whose disclosure could cause competitive harm, including details about a confidential partnership that NVIDIA had not publicly announced. The court found the proposed redactions minimal and narrowly tailored.

The court ordered the following materials sealed as designated by NVIDIA: portions of the Joint Status Report concerning the 30(b)(6) dispute; portions of Exhibits 1, 2, 3, 8, 10, 11, and 13; and all of Exhibits 5, 6, and 9. Publicly redacted versions of those materials were already available on the docket.

NVIDIA stated that it did not seek to seal Exhibits 4, 7, or 12. The court therefore ordered Valeo to file unredacted versions of those three exhibits publicly. The order was entered by Judge Virginia K. DeMarchi, United States Magistrate Judge.