Laatz v. Zazzle, Inc.
- Beth Freeman
- 5:22-cv-04844
- U.S. District Court · Northern District of California
- 6
In Laatz v. Zazzle, Judge Freeman granted in part and denied in part defendants’ request to seal summary-judgment materials.
Zazzle, Inc. and Mohamed Alkhatib must file a revised redacted summary-judgment motion within seven days. Nicky Laatz’s identified materials remain public, while specified portions of other exhibits may remain sealed; the order also determines which materials are available to the public.
What happened
In Laatz v. Zazzle, Inc., Defendants Zazzle, Inc. and Mohamed Alkhatib asked to seal portions of exhibits filed with their motion for summary judgment. Nicky Laatz opposed some requests and said she did not want other identified materials sealed.
The court applied the demanding standard for sealing records connected to a summary-judgment motion. It found that limited information about Zazzle’s internal license-purchasing and design-creation processes could cause competitive harm if disclosed, but that other information had already been publicly disclosed or was not requested by Laatz to be sealed.
Judge Beth Labson Freeman granted in part and denied in part the sealing motion. The court allowed specified portions of Exhibits F, U, Y, and Z to remain sealed, denied sealing for Exhibit KK and Exhibits C, N, O, Q, CC, DD, and required defendants to file a revised publicly redacted summary-judgment motion within seven days.
The detailed version
- Laatz v. Zazzle, Inc. · No. 5:22-cv-04844
- Beth Freeman
- Feb. 5, 2025
Background
Defendants Zazzle, Inc. and Mohamed Alkhatib filed an administrative motion asking to seal portions of exhibits submitted with their motion for summary judgment. The request concerned exhibits to the declaration of Thomas Nolan. Nicky Laatz filed a statement opposing the sealing request. She stated that she did not request sealing for Exhibits C, N, O, Q, CC, and DD, and opposed sealing of the other requested materials.
Legal standard
Because the materials supported a motion for summary judgment, the court applied the “compelling reasons” standard. Under that standard, a party seeking to seal judicial records must show specific reasons why disclosure would cause harm that outweighs the public’s strong interest in access to court records. The court also required the request to be narrowly tailored and supported by evidence.
Rulings on the exhibits
The court denied the request to seal Exhibits C, N, O, Q, CC, and DD because Laatz did not ask that those materials be sealed.
The court granted the request to seal narrowly identified portions of Exhibits F, U, Y, and Z. Those portions contained confidential information about Zazzle’s internal processes for purchasing licenses and creating designs. The court found that public disclosure could harm Zazzle’s competitive position.
The court denied the request to seal the highlighted portions of Exhibit KK. That exhibit concerned the technical operation and location of Zazzle’s proprietary Design Tool and font software, but the court found that the information had already been publicly disclosed on the docket.
Disposition
The court granted in part and denied in part defendants’ administrative motion to file under seal and to consider whether another party’s material should be sealed. It ordered defendants to file a revised redacted version of their motion for summary judgment on the public docket within seven days of the order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.