Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation
- Virginia Demarchi
- 5:23-cv-05721
- U.S. District Court · Northern District of California
- 5
In Valeo Schalter v. NVIDIA, Judge DeMarchi ordered specified materials sealed, did not grant one request entirely, and required public redacted filings.
Valeo Schalter und Sensoren GmbH and NVIDIA Corporation, as well as the public’s access to materials filed in connection with their discovery disputes.
What happened
Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation concerns requests to seal information connected to the parties’ discovery disputes. Valeo filed motions asking to seal materials or to evaluate NVIDIA’s sealing requests, and NVIDIA supported sealing with declarations.
The court applied a lower standard requiring a showing of good cause because the discovery disputes were only indirectly related to the case’s merits. NVIDIA identified confidential employee, project, source-code, system, and security information. Valeo identified source-code structure, trade secrets, and employee personal information.
Judge Virginia K. DeMarchi ordered the specified portions and documents sealed, but did not grant NVIDIA’s request to seal Exhibit A to the additional-depositions report in its entirety. The court required the parties to file specified public redacted or unredacted versions by April 18, 2025.
The detailed version
- Valeo Schalter und Sensoren GmbH v. NVIDIA Corporation · No. 5:23-cv-05721
- Virginia Demarchi
- Apr. 7, 2025
Background
Valeo filed administrative motions concerning the sealing of materials connected to recent discovery disputes. The opinion identifies the motions as Dkt. Nos. 209, 214, and 215, and notes that NVIDIA filed supporting declarations under Local Rule 79-5(f)(3). The materials concerned joint status reports and exhibits involving NVIDIA’s production of investigation documents and additional depositions.
Legal standard
The court explained that judicial records and documents accompanying motions that decide claims generally receive a strong presumption of public access. But discovery disputes are only tangentially related to the merits, so a party seeking to seal material in that setting must show “good cause” under Federal Rule of Civil Procedure 26(c). The court also reminded the parties that sealing entire documents is strongly discouraged and that they should seal only genuinely sensitive information when possible.
Reasons for sealing
NVIDIA asserted that good cause supported sealing information about employees only tangentially connected to the litigation; confidential internal projects and source-code files; system and source-code-repository configurations; assignments of devices and network locations to employees; security measures, policies, and investigative tools; autonomous-driving features, algorithms, functions, code-file names, and file paths; code development and earlier code versions; code repositories; and internal investigations and information-security measures. NVIDIA said disclosure could harm its competitive standing and could potentially compromise its security.
Valeo asserted that other material included the structure and names of folders containing its source code, its trade secrets, and personally identifiable information of its employees.
Rulings and required filings
The court agreed that good cause existed to seal the information designated by NVIDIA and Valeo and ordered the specified portions or documents sealed. The order covered the portions identified in the court’s table for the joint status reports and their exhibits, including several exhibits ordered sealed in their entirety and other exhibits ordered sealed only in specified portions.
The court did not grant NVIDIA’s request to seal Exhibit A to Dkt. No. 213 (Dkt. No. 213-5) in its entirety. NVIDIA had not shown that all information in that document—including details concerning German investigations, NVIDIA’s response, an internal code audit, and source-code-repository practices—required sealing. The court noted that details of the investigation had already been filed publicly. NVIDIA was ordered to file a proposed redacted version consistent with prior sealing and redaction orders.
The court also ordered the following:
- Valeo must file a public redacted version of Exhibit A to Dkt. No. 208 reflecting the redactions at Dkt. No. 119-3. - NVIDIA must file an updated redacted version of Exhibit 2 to Dkt. No. 213 reflecting Valeo’s proposed redactions at Dkt. No. 215-3. The clerk must seal the currently redacted version at Dkt. No. 219-2. - Valeo must file a public redacted version of Exhibit 3 to Dkt. No. 213 reflecting the redactions at Dkt. No. 119-3. - NVIDIA must file a proposed redacted version of Exhibit A to Dkt. No. 213. - Valeo must file a public redacted version of Exhibit B to Dkt. No. 213 showing the portions already made public at Dkt. No. 119-3; the remainder must be filed under seal. - Valeo must file a public redacted version of Exhibit C to Dkt. No. 213 reflecting its proposed redactions at Dkt. No. 215-6. - Because neither party sought sealing for Exhibit D to Dkt. No. 213, Valeo must file a public unredacted version.
The required filings were due no later than April 18, 2025.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.