Apple Inc. v. Alivecor, Inc.
- Haywood Gilliam
- 4:22-cv-07608
- U.S. District Court · Northern District of California
- 4
In Apple v. Alivecor, Judge Gilliam denied Apple’s sealing motion without prejudice because Alivecor did not show specific harm from disclosure.
Apple Inc. and Alivecor, Inc., particularly the handling of the limited portions of Exhibit 6 that Alivecor sought to keep from public view.
What happened
Apple Inc. v. Alivecor, Inc. involved Apple’s request to determine whether part of an exhibit should remain sealed after Alivecor marked it confidential. The exhibit was attached to Apple’s opposition to Alivecor’s motion to pause the case while a patent review proceeded.
Alivecor asked to seal only tables listing its internal product codes and product release dates. It argued that the information was commercially sensitive and that disclosure could cause competitive harm. The court applied a “good cause” standard because the exhibit concerned a motion that was only indirectly related to the case’s merits.
Judge Haywood S. Gilliam, Jr. denied the motion without prejudice. He found that Alivecor’s general statements did not specifically explain how disclosure would harm its business. Alivecor may file a supporting declaration within seven days; otherwise, the parties must file a public version of the document unless they jointly request its withdrawal.
The detailed version
- Apple Inc. v. Alivecor, Inc. · No. 4:22-cv-07608
- Haywood Gilliam
- Sept. 18, 2025
Background
Apple moved for a determination about whether Exhibit 6 to its opposition to Alivecor’s motion to stay the case should be sealed. Alivecor had marked the exhibit confidential. The exhibit concerned a motion to pause the case while a patent review proceeded.
Alivecor sought to keep sealed only two portions of Exhibit 6: a table describing its internal product codes and a table describing release dates for its products. Alivecor argued that the tables contained commercially sensitive, generally unknown, or valuable trade-secret information concerning its products, business operations, and finances. It also stated that disclosure could place it at a commercial disadvantage, harm business relationships and plans, and cause competitive harm.
Legal standard
The court explained that requests to seal judicial records generally require a showing of “compelling reasons” that outweigh the public’s strong presumption of access. But documents attached to motions only indirectly related to the underlying claims are subject to the lower “good cause” standard under Federal Rule of Civil Procedure 26(c).
Because Exhibit 6 concerned a nondispositive motion to stay that was only indirectly related to the merits, the court applied the good-cause standard. The court also noted that when a document was designated confidential by another party, the designating party must file a statement or declaration explaining why the material should remain sealed within seven days of the sealing motion.
Court’s analysis
The court found that Alivecor’s declaration used general, boilerplate descriptions of potentially confidential material, including business strategies, customer relationship information, technical details, and trade-secret information. Alivecor did not specifically explain why disclosure of the internal product codes would affect its business relationships or cause competitive harm. The court also noted that the mere fact that product information is confidential does not by itself establish the specific harm needed to support sealing.
The court likewise found that Alivecor did not explain why disclosure of product release dates from years earlier—apparently information that might already be publicly available—would be prejudicial.
Disposition
Judge Haywood S. Gilliam, Jr. denied Apple’s motion without prejudice. Within seven days of the order, Alivecor may file a declaration supporting continued sealing of excerpts from Exhibit 6. Alternatively, the parties may submit a joint request to withdraw the document. If neither occurs, the parties must file a public version of the document.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.