Noble Security, Inc. v. Acco Brands Corporation
- Paul Gardephe
- 1:16-cv-09129
- U.S. District Court · Southern District of New York
- 2
In Noble Security v. Acco Brands, Judge Gorenstein denied sealing motions but allowed proper renewed applications before possible unsealing.
The parties seeking to seal documents and members of the public seeking access to court records.
What happened
Noble Security, Inc. v. Acco Brands Corporation involved applications to keep documents filed with the parties’ summary-judgment motions from public view. The parties mainly relied on confidentiality designations or gave explanations the court found too general.
The court denied all five sealing motions. It did not order the documents unsealed immediately, instead allowing a party to submit a new, detailed application by February 13, 2025, identifying each proposed redaction and explaining why it was justified. If no new application was filed, the court said it would order the documents unsealed.
Judge Gabriel W. Gorenstein also warned that requests to redact entire documents or large portions would likely be denied and that parties must seek the narrowest possible redactions.
The detailed version
- Noble Security, Inc. v. Acco Brands Corporation · No. 1:16-cv-09129
- Paul Gardephe
- Feb. 6, 2025
Background
The court considered five letter applications to seal documents submitted in connection with the parties’ motions for summary judgment. Sealing means restricting public access to filed court materials. The court applied the standards from Lugosch v. Pyramid Co. of Onondaga and related decisions, which require specific justification for limiting the public’s access to court records.
Reasoning
The court found that the applications were either conclusory or relied on the fact that the materials had been designated confidential under a confidentiality order. It explained that a confidentiality designation, the parties’ agreement, or the existence of a confidentiality order does not by itself justify sealing documents. The applications therefore did not satisfy the required standard.
Ruling
The court denied the motions to seal filed at Docket Nos. 146, 147, 157, 162, and 169. It did not order the documents unsealed at that time. Instead, it gave any party seeking continued sealing an opportunity to file a proper application by February 13, 2025. Each application must identify every portion proposed for redaction and explain in detail the legal justification for each redaction or related group of redactions.
The court warned that applications seeking to redact entire documents or large portions of documents would likely be denied. Parties were directed to propose the narrowest possible redactions. If no application was filed by the deadline, the court stated that it would order the sealed documents unsealed. The order also explained how an application itself should be filed if it contains material that the applicant believes should remain sealed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.