Advanced Technologies Group, Inc. v. L3Harris Technologies, Inc.

Background

Advanced Technologies Group, Inc. (ATGI) asked the court to continue the provisional sealing of parts of its complaint against L3Harris Technologies, Inc., formerly known as L3 Technologies, Inc. Judge Gregory Woods had previously ordered a redacted complaint filed publicly and an unredacted complaint filed under seal, with the provisional seal set to expire on August 21, 2025. ATGI asked the assigned judge to continue the seal indefinitely or, alternatively, extend it until L3Harris’s position could be determined.

ATGI alleged that L3Harris misappropriated and disclosed ATGI’s trade secrets and proprietary information in violation of federal and state law and several proprietary information agreements. The proposed redactions covered ATGI’s trade secrets concerning its Ram-Air Turbine design, also called an Air-Driven Power Generation system, and information that could potentially be L3Harris’s business information. ATGI said disclosure could harm its competitive position. ATGI also stated that it took no position at that time on whether the material potentially concerning L3Harris actually qualified as L3Harris’s business information under the agreements.

Legal standard

The court applied the three-part test used in the Second Circuit for sealing court documents. The court first considers whether the material is a judicial document, then weighs the presumption of public access, and finally balances that presumption against competing interests such as privacy interests, trade secrets, and confidential business information. ATGI did not dispute that its complaint was a judicial document.

Ruling

The application was granted. Judge Valerie Caproni found preliminarily that ATGI’s redactions effectively balanced its asserted privacy interests against the public’s right of access to judicial documents. The court nevertheless required L3Harris’s view on whether the redactions were proper and overbroad.

The court ordered L3Harris, within two weeks after appearing in the action, to meet and confer with ATGI and file a joint letter describing the parties’ positions on whether the redactions were overbroad. ATGI was directed to serve L3Harris with a copy of the order and file proof of service by Wednesday, August 20, 2025. The order does not state that the seal was made permanent.