Forkosh v. Fluent
Steven Forkosh, TAPP Market Influencers, LLC, Bruce Wayne Enterprises Inc. v. Fluent, LLC, Ryan Schulke, Donald Patrick, Ryan Perfit, and Patrick Sweeney
- Analisa Torres
- 1:25-cv-07967
- U.S. District Court · Southern District of New York
- 1
In Steven Forkosh v. Fluent, Judge Torres granted plaintiffs’ request to seal the complaint to protect confidential information.
The plaintiffs’ complaint remains sealed in its unredacted form. The defendants’ anticipated request for permanent redactions was not decided.
What happened
In Steven Forkosh, TAPP Market Influencers, LLC, and Bruce Wayne Enterprises Inc. v. Fluent, LLC, and the individual defendants, the plaintiffs asked to file their complaint under seal.
The defendants did not oppose sealing and said they intended to ask for permanent redactions. The plaintiffs showed that redacting the complaint was needed to avoid breaching certain agreements and to protect confidential information.
Judge Analisa Torres granted the request and ordered the unredacted complaint to remain sealed. She did not decide the defendants’ anticipated request for permanent redactions, and the Clerk was directed to terminate the sealing motion.
The detailed version
- Forkosh v. Fluent · No. 1:25-cv-07967
- Analisa Torres
- Nov. 25, 2025
Background
The plaintiffs asked to file the complaint under seal under Rule IV.A. of the court’s Individual Practices. The defendants did not oppose that request and stated that they intended to seek permanent redactions of the complaint.
Court’s Analysis
Judicial documents generally carry a presumptive public right of access under the common law. The court explained that it may balance public access against the effects of disclosure, including disclosure of confidential business information. The plaintiffs demonstrated that redaction was necessary to avoid breaching certain agreements between the parties and to protect confidential information.
Ruling
Judge Analisa Torres granted the plaintiffs’ request to seal the complaint. The unredacted complaint filed at ECF No. 19 shall remain under seal. The court did not consider the defendants’ request for permanent redactions because that request was not before the court. The Clerk of Court was directed to terminate the motion at ECF No. 15.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.