Woodward Park Partners, LLC v. Advanced Drainage Systems, Inc.
- John Cronan
- 1:25-cv-03064
- U.S. District Court · Southern District of New York
- 3
In Woodward Park Partners v. Advanced Drainage Systems, Judge Cronan granted limited sealing and redaction of irrelevant third-party engagement information to protect privacy and competitive interests.
Woodward Park Partners, LLC, Advanced Drainage Systems, Inc., the third-party entities named in the unrelated engagements, and members of the public seeking access to the filing.
What happened
Woodward Park Partners, LLC asked the court to keep an unredacted exhibit to its complaint sealed and to allow a redacted version. The exhibit concerns an agreement assigning rights connected to the plaintiff’s claims against Advanced Drainage Systems, Inc., but also names entities involved in unrelated engagements.
The plaintiff argued that those unrelated engagements were irrelevant to its claims and that public disclosure could reveal possible mergers or acquisitions, harming the entities’ privacy and competitive interests. The requested redactions were limited to information about those third-party engagements.
Judge Cronan granted the request. He ruled that the redacted information was irrelevant to the plaintiff’s claims, that the privacy and competitive interests outweighed public access, and that the request was narrowly tailored. The filing at ECF No. 1-3 will remain sealed, and the plaintiff must file the redacted version of Exhibit 3.
The detailed version
- Woodward Park Partners, LLC v. Advanced Drainage Systems, Inc. · No. 1:25-cv-03064
- John Cronan
- Apr. 25, 2025
Background
Woodward Park Partners, LLC asked the court to keep under seal the unredacted version of Exhibit 3 to its complaint and to permit it to file a redacted version. Exhibit 3 is an August 18, 2023, assignment and assumption agreement involving rights and obligations under a December 16, 2021, engagement agreement between Cowen & Company, LLC and Advanced Drainage Systems, Inc. The plaintiff’s claims arise from that engagement agreement.
The exhibit also identifies other engagement agreements that Cowen assigned to the plaintiff. The plaintiff said those other engagements involved third-party entities, were either ongoing or on hold with an expectation that they would resume, and were unrelated to the plaintiff’s claims against Advanced Drainage Systems. The plaintiff sought to redact the names of those entities, asserting that disclosure could reveal that they were exploring possible mergers or acquisitions and could cause privacy and competitive harm.
Court’s Analysis
The court granted the request. It found that the redacted information was irrelevant to the plaintiff’s claims. The court also determined that the privacy and competitive interests of the entities involved in the third-party engagements outweighed any presumption that the information should be publicly accessible.
The court further found that the sealing request was narrowly tailored to address the sensitivity of the information. Relying on the standards for sealing court filings under Lugosch, the court concluded that sealing was warranted.
Disposition
Judge John P. Cronan ordered that ECF No. 1-3 remain under seal and directed Woodward Park Partners to file the redacted version of Exhibit 3 to its complaint.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.