Rocket Pharmaceuticals, Inc. v. Lexeo Therapeutics, Inc.

Background

The parties submitted a joint letter concerning documents that Rocket and Lexeo had filed under seal in connection with discovery-related letter motions. The letter relied on the general public right to inspect judicial records and the rule that sealing must be supported by specific findings showing that it is necessary to protect a higher-value interest and is narrowly tailored.

The parties asserted that the documents contained confidential commercial information, including trade secrets, research and development information, gene-therapy information, internal employment decisions, manufacturing-partner information, and a drug-preparation protocol. The parties also noted that publicly accessible versions of some documents had been filed with redactions.

Rocket’s request

Rocket asked the court to seal Exhibit I to Lexeo’s reply letter motion, filed at ECF No. 157-3, and Exhibit B to Rocket’s first letter motion, filed at ECF No. 162-2. Rocket said that the documents described aspects of its gene-therapy programs, strategic manufacturing partners, and an internal adeno-associated-virus drug-preparation protocol. Rocket characterized the information as nonpublic and competitively sensitive, including trade secrets protected under the federal Defend Trade Secrets Act.

Rocket took no position on whether Lexeo’s documents at ECF Nos. 157-1, 162-1, and 165-1 contained Lexeo’s purported trade secrets, but did not oppose Lexeo’s request to keep those documents under seal.

Lexeo’s request

Lexeo asked the court to seal Exhibit G to its reply, filed at ECF No. 157-1; Exhibit A to Rocket’s first letter motion, filed at ECF No. 162-1; and Exhibit A to Rocket’s second January 28, 2025 letter motion, filed at ECF No. 165-1. Lexeo said the documents contained confidential information about research and development related to a trade secret asserted in its counterclaims, gene therapies, and internal employment decisions. Lexeo argued that redacted public versions were the least restrictive way to protect its confidential information.

Lexeo disagreed that ECF Nos. 157-3 and 162-2 reflected Rocket’s purported trade secrets, but did not oppose Rocket’s request to keep those documents under seal.

The parties also jointly requested that ECF No. 157-2 temporarily remain under seal. That document overlapped with ECF No. 142-5, and the parties sought to keep it sealed while completing the process described in the court’s January 29, 2025 order.

Ruling

Judge Castel granted the joint letter motion to seal with respect to ECF Nos. 157-1, 157-3, 162-1, 162-2, and 165-1. After reviewing redacted and unredacted versions, the court found that the parties had met their burden for sealing the redacted portions of ECF Nos. 157-1, 162-1, 162-2, and 165-1. The court separately found that Rocket had met its burden to seal the complete document at ECF No. 157-3.

The court deferred ruling on the extent to which ECF No. 157-2 would remain under seal while the parties completed the process required by the January 29, 2025 order. The order addressed document access and confidentiality; it did not decide the parties’ underlying claims or counterclaims.