Barcomb v. Wireless
- Naomi Buchwald
- 1:24-cv-08710
- U.S. District Court · Southern District of New York
- 2
In Barcomb v. TracFone, Judge Buchwald granted plaintiffs’ application to file a settlement administrator’s fraud-prevention declaration under seal.
Plaintiffs and proposed class counsel may file the supplemental declaration under seal; Kroll Settlement Administration’s fraud-prevention information will not be publicly filed under this ruling.
What happened
Barcomb, et al. v. TracFone Wireless, Inc. concerns plaintiffs’ request to submit an additional declaration supporting their motion for final approval of a class-action settlement.
The declaration would describe Kroll Settlement Administration’s methods for detecting and preventing fraudulent claims. Plaintiffs said public disclosure could reveal those methods and make it harder for Kroll, a non-party, to prevent fraudulent submissions.
Judge Naomi Reice Buchwald granted the application, allowing the supplemental declaration to be filed under seal rather than publicly.
The detailed version
- Barcomb v. Wireless · No. 1:24-cv-08710
- Naomi Buchwald
- Sept. 9, 2025
Background
Plaintiffs asked to file under seal—that is, with restricted public access—a supplemental declaration from Kroll Settlement Administration in support of plaintiffs’ motion for final approval of a class-action settlement. Kroll is a non-party settlement administrator.
Request and Reasons
The requested declaration concerns Kroll’s procedures and policies for detecting and preventing fraud. Plaintiffs argued that the declaration contains specific details about Kroll’s anti-fraud efforts and that public disclosure could undermine those efforts by revealing the methods and techniques Kroll uses to combat fraudulent claim submissions. Plaintiffs also cited the privacy interests of non-parties and the potential competitive harm from disclosing confidential business information.
Ruling
Judge Naomi Reice Buchwald granted the application. The opinion therefore permitted plaintiffs to file Kroll’s supplemental declaration regarding fraud-prevention measures under seal. The text does not specify any additional conditions or a time limit for the sealing order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.