Strike 3 Holdings, LLC v. Doe

Background

Strike 3 Holdings, LLC asked for permission to file an unredacted version of its affidavit of service under seal. The information it sought to keep confidential was the defendant’s personally identifiable information. The request was made by a letter dated March 13, 2025.

Court’s analysis

The court applied a three-step test for sealing court filings. First, it determined whether the document was a “judicial document”—a filing relevant to the court’s work and useful in the judicial process. Second, it assessed the strength of the public’s presumptive right to access the document. Third, it identified legitimate reasons against disclosure and balanced them against public access.

The court concluded that the affidavit was a judicial document. It gave the public-access presumption moderate weight because the information could help the public monitor the court’s exercise of its authority. But the court found that the defendant’s privacy interests outweighed the public interest in disclosure at this time. The court emphasized that Strike 3 sought confidentiality only provisionally, until the defendant had an opportunity to be heard regarding the privacy interest.

Ruling and directives

Judge Woods granted the motion to file the unredacted affidavit of service under seal with respect to the specified redactions. The court limited its decision to the information at issue, the current stage of the case, and the record before it. Strike 3 was directed to serve the order on the defendant and retain proof of service. The clerk was directed to terminate the motion at Docket No. 26.