Sandisk Storage Malaysia Sdn. Bhd., et al. v. Viasat, Inc.

Background

The court considered Sandisk’s amended administrative motion to determine whether materials submitted by another party should be sealed. Sandisk had submitted the proposed sealed materials in support of its opposition to Viasat’s motion for summary judgment of noninfringement.

In an earlier ruling, the court found that Sandisk had met the “compelling reasons” standard for sealing materials attached to dispositive motions, but had not narrowly tailored its request. Sandisk’s exhibits covered more than 2,000 pages, while Sandisk cited only a limited number of pages. The court ordered Sandisk to file an amended motion with appropriately limited excerpts from Exhibits 14–18, 20, 22, 23–25, 27, and 32.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. A party seeking to seal records attached to a dispositive motion must show compelling reasons supported by specific facts that outweigh the public’s interest in disclosure. The party must also consider reasonable alternatives, limit the number of sealed documents, avoid sealing entire documents when possible, explain the injury that would result from disclosure, and show why less restrictive alternatives would not be sufficient.

Ruling

Sandisk refiled its motion with fewer pages, reducing the total page count by 796 pages from the exhibits covered by the court’s earlier order. Viasat did not file an objection or response to the amended motion. After reviewing the materials, Judge Haywood Gilliam found that the amended request, together with Viasat’s prior arguments, satisfied the applicable requirements.

The court granted Sandisk’s amended administrative motion to file the materials under seal. Under Civil Local Rule 79-5(g)(1), the documents filed under seal will remain under seal.