Mattson Technology, Inc. v. Applied Materials, Inc.

Background

The order concerns administrative motions to seal documents filed in connection with Applied Materials, Inc.’s motion to disqualify. The motions involved Applied Materials’ motion, Mattson’s opposition, Applied Materials’ reply, supporting declarations and exhibits, and demonstrative slides from a September 16, 2025 hearing. The opinion states that the parties sought to seal both their own information and each other’s information. No party opposed another party’s motions. Applied Materials filed a supporting statement for the request concerning information attributed to Applied Materials. Mattson did not file a supporting statement for its request concerning Mattson’s information.

Legal standard

The court explained that court records are generally presumed to be open to public inspection. Because the motion to disqualify was only tangentially related to the merits of the underlying case, the court applied the lower “good cause” standard rather than the “compelling reasons” standard. The court stated that proprietary business information, including internal investigations and procedures relating to intellectual property and trade secrets, may satisfy the good-cause standard when the proposed redactions are appropriate. It also stated that not all confidential information concerning legal counsel automatically qualifies for sealing and that sealing must be narrowly tailored.

Rulings on the documents

The court granted in part and denied in part the requests to seal specified portions of Applied Materials’ motion to disqualify, Nathan Zhang’s declaration, Exhibit 3 to Christina E. Myrold’s declaration, Mattson’s opposition, Applied Materials’ reply, and Applied Materials’ demonstrative slides. For those documents, the court permitted only the specified portions, as modified in the order, to remain sealed because they contained Applied Materials’ nonpublic confidential information that could cause harm if disclosed. The court denied the broader proposed redactions as overbroad.

The court granted Applied Materials’ request to seal the identified portion of paragraph 11 of Christina E. Myrold’s declaration. It denied the requests concerning Mattson’s information in that declaration because Mattson had not filed a supporting statement. The court denied sealing Exhibit 2 to the Myrold declaration, including Applied Materials’ information, because the bare fact that an individual was involved in Applied Materials’ internal investigations into Mattson, without details about those investigations, did not justify sealing. It also denied the requests concerning Mattson’s information in that exhibit because Mattson had not filed a supporting statement.

The court granted the request to seal the identified blue-highlighted portion of Mattson’s opposition and the identified blue-highlighted text in J. Parks Workman’s declaration. It denied requests concerning Applied Materials’ information in Exhibits 1 and 2 to Mattson’s opposition because Applied Materials had not sought to seal that information in its supporting statement. The court also held that neither the bare fact of the individual’s involvement in Applied Materials’ internal investigations into Mattson nor the simple length and title of that person’s tenure at Applied Materials warranted sealing.

Disposition and required filings

The order states that the administrative motions to seal were granted in part and denied in part. The Clerk of Court was ordered to unseal Dockets 158-6, 167-6, and 167-7, and to maintain Dockets 158-3, 158-4, 158-5, 158-7, 166-4, 166-6, 171-3, and 180-3 under seal. By October 6, Applied Materials was required to publicly file narrower redacted versions of the documents identified by the court. By the same date, Mattson was required to publicly file a narrower redacted version of Docket 166-4; the court stated that Mattson did not need to file a narrower version of Docket 166-6. The order warned that failure to submit proper public redacted versions could result in unsealing of the corresponding docket entry.