Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com…
Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com Services LLC
- Lorna Schofield
- 1:23-cv-00292
- U.S. District Court · Southern District of New York
- 3
Binh Thanh v. Amazon.com Services, Judge Schofield granted Amazon’s motions to seal or redact filings connected to Amazon’s summary-judgment motion.
Amazon.com Services LLC’s filings will remain sealed or partially redacted as ordered, limiting public access to specified confidential business and legal information; the order also affects Binh Thanh’s opposition exhibit that Amazon sought to seal entirely.
What happened
In Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com Services LLC, Amazon asked to seal or redact parts of the written arguments, exhibits, and factual statements filed with its motion for summary judgment. Binh Thanh took no position on the requests.
Judge Schofield explained that these filings are judicial documents because they help the court decide the case and are generally presumed to be open to the public. A party seeking to seal them must show that protecting a more important interest—such as confidential business information—outweighs public access. The court found that Amazon’s proposed redactions were limited and protected specific confidential business and legal strategies from competitive harm. It also found that fully sealing one exhibit was appropriate because confidential information was spread throughout it.
Judge Schofield granted the sealing motions at docket numbers 90, 96, 100, and 107. This order addressed only access to the filings and did not decide the underlying summary-judgment motion.
The detailed version
- Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com… · No. 1:23-cv-00292
- Lorna Schofield
- Mar. 5, 2025
Background
Amazon.com Services LLC, doing business as Amazon Robotics, moved to seal or redact portions of documents filed in connection with its motion for summary judgment. The requested sealing covered parts of the parties’ legal memoranda, statements of material facts under Federal Rule of Civil Procedure 56.1, declarations, and exhibits. Amazon sought limited redactions in each document except one exhibit to Binh Thanh’s opposition, which Amazon sought to file entirely under seal. Binh Thanh took no position on the requests.
Legal standard
The court applied a three-step test for sealing documents. First, it asked whether the materials were judicial documents subject to a presumption of public access. Second, it considered how much weight that presumption deserved based on the materials’ role in the court’s exercise of its authority. Third, it balanced public access against competing interests, including privacy and the protection of sensitive commercial information. The party seeking secrecy bears the burden of showing that a more important interest outweighs public access. Any sealing must be supported by specific findings and must be narrowly tailored.
Court’s analysis
The court found that all the materials at issue were judicial documents because they were submitted in connection with a summary-judgment motion and were relevant to the court’s work. The court also found that Amazon’s proposed redactions concerned confidential business and legal information. Based on its review of the proposed redactions and prior sealing orders in the case, the court determined that the limited redactions protected specific business and legal strategies from competitive harm and were narrowly tailored. The court further found that fully sealing the one exhibit was appropriate because confidential information was pervasive throughout that document.
Disposition
The court ordered that Amazon’s sealing motions at Docket Nos. 90, 96, 100, and 107 were GRANTED. The opinion did not rule on the merits of the underlying summary-judgment motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.