NGI Capital, Inc. d/b/a Apex IT v. Watlow Electric Manufacturing Company
- P. Castel
- 1:25-cv-05683
- U.S. District Court · Southern District of New York
- 3
In NGI Capital v. Watlow, Judge Castel denied NGI’s sealing motion and ordered unredacted filings publicly docketed, subject to limited permitted redactions.
NGI Capital, Watlow Electric Manufacturing Company, the employees whose names appeared in the filings, and members of the public who may access the court docket.
What happened
NGI Capital, Inc. d/b/a Apex IT v. Watlow Electric Manufacturing Company is a contract dispute over unpaid IT services related to software made by Oracle Corporation. NGI asked to seal employee names in its amended complaint and all 19 attached exhibits.
Watlow opposed the request. The court found that the amended complaint was a judicial document subject to a strong presumption of public access, and that NGI had not shown a sufficiently strong, narrowly tailored reason for sealing the materials. The court also noted that two important documents were already publicly filed.
Judge Castel denied the motion to seal. He ordered unredacted versions filed on the public docket within five days, while allowing redaction of email addresses, phone numbers, and material permitted under Federal Rule of Civil Procedure 5.2.
The detailed version
- NGI Capital, Inc. d/b/a Apex IT v. Watlow Electric Manufacturing Company · No. 1:25-cv-05683
- P. Castel
- Oct. 20, 2025
Background
NGI Capital, Inc. d/b/a Apex IT brought a diversity action against Watlow Electric Manufacturing Company concerning alleged non-payment for IT services. The claims are for breach of contract, quantum merit, unjust enrichment, and account stated. The work involved implementing a customer-experience software product made by Oracle Corporation.
NGI asked to seal the names of individuals employed by either party who were listed in the First Amended Complaint and all 19 exhibits attached to that complaint. The exhibits included contractual documents and other materials, including a PowerPoint presentation, emails, outstanding balances, and change orders. NGI characterized the materials as confidential and proprietary and asserted that the parties had agreed to confidentiality. Watlow opposed the application entirely.
Court’s Analysis
The court held that the First Amended Complaint was a judicial document, meaning a court filing to which the public-access presumption applies. The presumption was strong because the complaint explained the nature of the action to interested members of the public. The court concluded that NGI had not shown countervailing considerations strong enough to justify sealing, nor had it shown that sealing was essential to higher values and narrowly tailored to protect those values.
The court also noted that the Master Services Agreement and Statement of Work contained employee names and pricing information but had already been publicly filed since September 8, 2025. Those documents were not the subject of the application and would remain public even if the motion were granted.
The court declined to review the 19 exhibits line by line because NGI had not provided a detailed explanation identifying why particular text should be sealed. The court stated that the application was poorly considered, distracted from other litigants’ needs for judicial attention, and increased Watlow’s defense costs.
Ruling
Judge P. Castel denied the motion to seal, identified as ECF 16. The court ordered unredacted versions to be filed on the public docket within five days. It permitted redaction of email addresses and phone numbers in the exhibits to the First Amended Complaint, as well as any material that may be redacted under Federal Rule of Civil Procedure 5.2.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.