Cellink Corp. v. Manaflex LLC

Background

Manaflex LLC filed an administrative motion asking the court to consider whether material belonging to another party should be sealed. The motion concerned limited portions of Manaflex’s opposition to CelLink Corp.’s declaration supporting a renewed request to file parts of its second amended complaint under seal. Manaflex had attached an unredacted version of the complaint to its opposition.

The materials at issue included portions of paragraphs 14–16, 22, 128, 136, and 144–145 of the second amended complaint, as well as lines 13–19 of page 2 of Manaflex’s opposition. CelLink had designated the material “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY.” CelLink’s counsel submitted a declaration stating that the material disclosed confidential and trade-secret manufacturing processes for flexible circuits. The declaration said public disclosure could cause irreparable damage because competitors could gain an unfair advantage, and it described CelLink’s efforts to protect the information from public disclosure and unauthorized use.

Legal standard

The court explained that documents attached to a motion that could resolve the case generally may be sealed only for “compelling reasons” that outweigh the public’s strong interest in access to court records. The court applied that standard to the second amended complaint because it was the pleading on which the action was based.

For documents attached to motions that do not resolve the case, the court applies the lower “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a specific showing that disclosure would cause particular harm or prejudice. The court determined that Manaflex’s opposition was not filed in connection with a dispositive motion, so the good-cause standard applied to that material.

Ruling

The court found that CelLink had satisfied the compelling-reasons standard for the identified portions of the second amended complaint. It determined that those sections reflected CelLink’s confidential and trade-secret information and that the reasons for protecting the information outweighed the public’s interest in viewing it.

The court also found that the identified lines in Manaflex’s opposition contained sensitive trade-secret information that CelLink had sought to protect and that public disclosure could cause CelLink economic harm. The court concluded that CelLink’s declaration satisfied the good-cause standard.

Accordingly, the court granted Defendant Manaflex LLC’s administrative motion to consider whether another party’s material should be sealed, Docket No. 140.