McKeon Rolling Steel Door Co., Inc. v. U.S. Smoke & Fire Corp.

Background

The parties filed several motions to seal documents submitted in connection with their competing motions for summary judgment. McKeon asked to seal portions of deposition transcripts and related exhibits concerning Andrew Lambridis and Steven Sadeghian, as well as U.S. Smoke & Fire product quotations. McKeon later filed three additional deposition-related exhibits under seal.

Defendants separately moved to seal documents supporting their cross-motion for summary judgment, documents submitted in opposition to McKeon’s motion, and documents submitted with their reply. The materials included emails, deposition excerpts, interrogatory responses, testing notes and reports, copyrighted material concerning the 10B Standard for Safety, and other documents. Defendants stated that some materials had been filed under seal out of an “abundance of caution.”

Although the motions were directed to Judge Carter, they fell within Judge Tarnofsky’s referral for general pretrial supervision.

Legal standard

The court explained that judicial documents—documents useful to the judicial process—are presumed to be accessible to the public. Because the documents here were submitted with dispositive motions, they carried a substantial presumption of public access. The court therefore had to balance that presumption against interests favoring confidentiality, including privacy and protection from competitive harm.

The court also explained that information need not qualify as a formal trade secret to receive protection from disclosure. Relevant considerations include how widely the information is known, the steps taken to protect it, its value to the business and competitors, the effort or money used to develop it, and how easily others could acquire or duplicate it.

Rulings

The court reviewed the documents McKeon sought to seal and concluded that the information was not likely to be known outside the company, that McKeon took measures to protect it, and that disclosure could cause competitive harm. McKeon’s First Motion to Seal, ECF 143, was therefore granted. Documents McKeon filed under seal at ECF 180 were also allowed to remain sealed.

The court did not decide whether the documents defendants sought to seal could remain sealed. Instead, it ordered the parties to meet and confer about whether any of those documents could be filed publicly. By September 9, 2025, the parties had to file a joint letter identifying documents that need not remain sealed and explaining why any documents they continued to seek to protect should remain sealed.

The conclusion also requested that the Clerk terminate ECF 143, 174, and 180. The order addressed access to court filings and did not decide the parties’ underlying summary-judgment motions.