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: Judge Schofield denied requests to seal filing portions and courtroom, finding claimed harm from revealing past fraud too speculative.
The ruling affects the plaintiff’s efforts to keep portions of its filing and the evidentiary hearing closed, and preserves public access to the identified court materials and proceeding.
What happened
In Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com Services LLC, the plaintiff asked to seal limited portions of a filing and to close an upcoming evidentiary hearing. It argued that disclosure could reveal competitively sensitive information about its operations and internal vulnerabilities.
The court denied both requests. It held that the plaintiff’s claimed harm from disclosure of a past fraud was speculative and did not overcome the strong presumption that judicial documents and court proceedings should be public. The court distinguished cases involving ongoing anti-fraud systems whose disclosure could help people evade those systems.
Judge Schofield directed the Clerk of Court to unseal Docket No. 238 and close the motion at Docket No. 236. The opinion therefore addressed courtroom access and document sealing, not the underlying dispute between the parties.
The detailed version
- Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com… · No. 1:23-cv-00292
- Lorna Schofield
- Aug. 8, 2025
Background
The plaintiff, referred to in the filing as Gilimex, asked the court to seal narrowly limited portions of an August 7, 2025 letter concerning an upcoming August 12, 2025 evidentiary hearing. It also asked the court to keep the courtroom closed during all or part of that hearing. The plaintiff argued that public disclosure could reveal competitively sensitive information about its operations and internal vulnerabilities, which could be used to its detriment or inspire similar fraud schemes.
Court’s analysis
The court stated that the presumption of public access to judicial documents can be overcome only through specific findings that closure is essential to preserve higher values. It rejected the plaintiff’s reliance on cases involving anti-fraud or fraud-assessment programs. Those cases concerned proprietary methods whose disclosure could allow bad actors to evade or manipulate ongoing fraud-prevention systems.
The court found the plaintiff’s request materially different because it sought to protect descriptions of a past fraud and its circumstances, rather than ongoing fraud-prevention mechanisms. It concluded that the plaintiff’s asserted harm was speculative and insufficient to overcome the strong presumption of public access. The court reached the same conclusion regarding closing the evidentiary hearing.
Ruling and effect
The application to seal the filing was DENIED. The application to seal the courtroom for the evidentiary hearing was also DENIED. The Clerk of Court was directed to unseal Docket No. 238 and close the motion at Docket No. 236. The order concerned access to court documents and proceedings; it did not decide the underlying claims in the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.