Artisan Technologies LLC v. Interlude U.S. Inc.
- Lorna Schofield
- 1:25-cv-07214
- U.S. District Court · Southern District of New York
- 3
In Artisan Technologies v. Interlude, Judge Schofield denied without prejudice Artisan's motion to seal Complaint Exhibit A.
Artisan Technologies LLC must either file an amended complaint omitting Exhibit A or renew its motion to seal by September 30, 2025. The order also affects public access to the complaint exhibit and concerns allegations involving Interlude U.S. Inc.
What happened
Artisan Technologies LLC asked to keep Exhibit A to its complaint under seal, saying the exhibit described its confidential Donatello Arm Operating System and other business information.
The court said complaint exhibits are generally open to the public. Although some parts of Exhibit A might contain confidential information, other parts appeared to show public websites, industry practices, or other material that did not appear confidential. Replacing the entire exhibit with a cover sheet was therefore broader than necessary. The court also did not decide whether the complaint met any pleading requirement.
Judge Lorna G. Schofield denied Artisan's motion to seal without prejudice to renewal. She ordered Artisan, by September 30, 2025, either to file an amended complaint omitting Exhibit A or to file a renewed sealing motion.
The detailed version
- Artisan Technologies LLC v. Interlude U.S. Inc. · No. 1:25-cv-07214
- Lorna Schofield
- Sept. 16, 2025
What the court considered
Artisan Technologies LLC moved to file Exhibit A to its complaint under seal. Artisan stated that sealing was needed to prevent unauthorized disclosure of confidential business information concerning its secret Donatello Arm Operating System.
Legal standard
The court applied the three-part test for sealing judicial documents. First, it asked whether the material was subject to the public's presumed right of access. Second, it considered the strength of that presumption based on the material's role in the exercise of federal judicial power and its value to people monitoring the courts. Third, it balanced the presumption against competing interests, including the protection of specific business information and strategies. Any sealing must be supported by specific findings and narrowly tailored to protect the competing interest.
Reasoning
The court held that Exhibit A was a judicial document subject to a strong presumption of public access because it was attached to the complaint. Artisan had not shown that its proposed redaction was narrowly tailored. Some portions appeared plausibly to contain Artisan's confidential business information, and every page was marked “Confidential & Proprietary.” But other portions appeared to contain links and screenshots of publicly available websites, descriptions of industry-wide practices, and other material that did not, without more, appear confidential. Artisan's proposal to replace the entire exhibit with a slipsheet therefore covered more material than necessary.
The court also stated that it was not expressing a view on whether the complaint satisfied any applicable pleading standard. At that stage, it was not clear that a trade-secret addendum was necessary to give Interlude fair notice of Artisan's claim, because the complaint alleged that Interlude misappropriated trade secrets, including the Donatello Arm Operating System, and described those secrets in agreements between the parties.
Disposition
Judge Lorna G. Schofield denied Artisan's motion to seal without prejudice to renewal. The court ordered Artisan to file, by September 30, 2025, either an amended complaint omitting Exhibit A or a renewed motion to seal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.