SQIP, LLC v. Cambria Company LLC
- Dulce Foster
- 0:24-cv-01111
- U.S. District Court · District of Minnesota
- 7
Counsel of record per CourtListener. Firm names are approximate.
In SQIP, LLC v. Cambria Company LLC, Magistrate Judge Foster granted one sealing motion and granted in part and denied in part a second, ordering some court filings unsealed unless parties refile narrower redactions by September 3, 2026.
Parties to intellectual property litigation who file sensitive business documents — such as trade secrets, financial records, and licensing agreements — in court, and members of the public who have an interest in accessing court records. The ruling also signals to litigants in this district that overbroad confidentiality designations from discovery will not automatically justify sealing documents filed on the public court docket.
What happened
SQIP, LLC v. Cambria Company LLC is a case before the U.S. District Court for the District of Minnesota involving a dispute in which both parties filed joint motions asking the court to keep certain documents permanently sealed from public view. These documents had been filed in connection with earlier discovery disputes, including a motion to compel inspection of a manufacturing facility, motions to compel production of financial records, and a motion to amend infringement contentions.
The court applied two different standards depending on whether a federal district judge (an Article III judge) had reviewed the underlying materials. For documents tied to a motion that only a magistrate judge decided, the bar for continued sealing is lower — a legitimate business reason is enough. For documents that played a role in a ruling by a district judge, the parties must show compelling reasons. The court found the first category met the lower standard because the documents contain competitively sensitive and proprietary information. For the second category, the court found that while many exhibits warranted continued sealing for the same reasons, the redactions in several legal briefs were overbroad — in some instances parties labeled as trade secrets things like general descriptions of data fields or a document's own caption page.
Magistrate Judge Foster granted the first sealing motion in full and granted in part and denied in part the second. Several specific documents were ordered kept under seal. However, certain briefs (ECF Nos. 154, 159, 176, and 181) will be unsealed unless the parties file a new, properly narrowed sealing motion by September 3, 2026, accompanied by more carefully redacted versions of those documents. Two declarations already publicly available were ordered unsealed. The parties were also directed to file a motion by September 3, 2026 addressing one exhibit (ECF No. 148-4) that neither party discussed, or the court will order it unsealed.
The detailed version
- SQIP, LLC v. Cambria Company LLC · No. 0:24-cv-01111
- Dulce J. Foster
- Aug. 13, 2026
Background
This intellectual property case involves SQIP, LLC as plaintiff and Cambria Company LLC as defendant. Over the course of litigation, various documents were filed under seal in connection with discovery disputes. Two joint motions for continued sealing were filed by the parties together asking the court to keep those documents permanently sealed.
The first sealing motion (ECF No. 132) arose from briefing on SQIP's motion to compel a physical inspection of Cambria's manufacturing facility, which Magistrate Judge Foster had previously denied (ECF No. 124). The second sealing motion (ECF No. 197) arose from briefing on SQIP's motions to compel production of financial records and a licensing agreement (ECF No. 133) and to amend infringement contentions (ECF No. 144). The magistrate judge granted both of those underlying motions in part (ECF No. 167), and District Judge Nancy E. Brasel affirmed that order over SQIP's objections (ECF No. 192).
Legal Standard Applied
The court explained that there is a common-law right of public access to judicial records, but that right is not absolute. Courts must balance interference with public access against the interests served by keeping information confidential, and the weight given to the presumption of public access depends on how central the material was to the exercise of federal judicial power (Article III power).
When documents played a material role in a decision by an Article III judge (a federal district judge), the presumption of public access is strong and can only be overcome by compelling reasons. When documents did not play such a role — for instance, when they were filed in connection with a non-dispositive motion decided only by a magistrate judge — the standard is lower: a legitimate countervailing reason suffices.
First Sealing Motion (ECF No. 132)
Because Magistrate Judge Foster, not a district judge, ruled on the inspection motion underlying this sealing request, the lower threshold applied. The court found that the parties' representations that the documents contain competitively sensitive and proprietary information constituted a sufficient countervailing reason to overcome the prediction of public access.
The court rejected the argument that documents should remain sealed simply because they were designated "Highly Confidential – Attorneys' Eyes Only" in discovery, noting that discovery designations are not dispositive of whether a document should be sealed on the public court docket. However, based on the substance of the materials, the court granted continued sealing.
The court also noted that a declaration by Eimeric Reig-Plessis had been filed both publicly (ECF No. 120) and under seal (ECF No. 121). Because the parties did not ask to keep ECF No. 121 sealed — logically, since it was already publicly available — the court ordered ECF No. 121 unsealed, while keeping its attached exhibits (ECF Nos. 121-1 through 121-4) sealed.
The court added that its ruling keeping documents sealed at this stage has no preclusive effect on how District Judge Brasel might handle the same documents in ruling on any dispositive motions or at trial.
Second Sealing Motion (ECF No. 197)
Because District Judge Brasel reviewed and affirmed the rulings on the underlying motions to compel and to amend infringement contentions, these documents played a material role in the exercise of Article III judicial power. The higher "compelling reasons" standard therefore applied.
Briefs (Memoranda)
The parties sought to permanently seal unredacted versions of their legal briefs (ECF Nos. 145, 154, 159, 176, and 181), with publicly filed versions containing redactions the parties characterized as concealing "trade secret information." The court found the redactions overbroad. Examples the court cited of doubtful redactions included: descriptions of spreadsheets without revealing their content; a document caption labeling the brief itself as filed "under seal"; the time period for budget information; and general descriptions of data field types in financial reports without disclosing any actual data.
The court accepted the redactions in ECF No. 145, which described Cambria's manufacturing process, and noted that not every redaction was unwarranted — for instance, redactions describing terms of a settlement agreement were treated as appropriate. But the overall set of redactions submitted was "plainly overbroad."
The court declined to go through the briefs itself to identify which redactions are proper, stating that is the parties' job. It denied the sealing motion as to ECF Nos. 154, 159, 176, and 181, directing the parties that if they wish to keep any part of those briefs sealed, they must file a new motion under Local Rule 5.6(f) by September 3, 2026, with more narrowly redacted versions that counsel can sincerely represent conceal trade secrets or similarly sensitive information. Those documents will be unsealed if no such motion is filed by that deadline.
Exhibits
For the sealed exhibits (ECF Nos. 137, 139, 139-1 to 139-2, 148, 148-1 to 148-3, 157, 161, 163-1 to 163-10, 173-1, and 176-1), the court reviewed each document and found continued sealing appropriate because each contains confidential and sensitive or proprietary trade secret, financial, or other business information. The court again rejected the discovery-designation rationale but found the substantive content justified sealing under the compelling reasons standard.
Declarations and One Memorandum
As with the first motion, a Reig-Plessis declaration had been filed both publicly (ECF No. 162) and under seal (ECF No. 163); the court ordered ECF No. 163 unsealed. The parties also agreed that the memorandum at ECF No. 173 no longer needed to remain sealed, so the court ordered it unsealed.
Unaddressed Exhibit
Plaintiff filed Exhibit 16 to its motion to amend (ECF No. 148-4) under seal, but the parties inadvertently failed to address it in their second sealing motion. The court directed the parties to file a motion to continue sealing ECF No. 148-4 pursuant to Local Rule 5.6(d) by September 3, 2026, or the court will order it unsealed.
Disposition
- First Joint Motion for Continued Sealing (ECF No. 132): GRANTED. - Second Joint Motion for Continued Sealing (ECF No. 197): GRANTED IN PART and DENIED IN PART. - Numerous identified exhibits ordered kept under seal. - ECF No. 145 (one brief): sealing accepted. - ECF Nos. 154, 159, 176, and 181 (four briefs): denied; those documents will be unsealed unless parties file a proper, narrowly redacted new motion by September 3, 2026. - ECF Nos. 121, 163, and 173: ordered unsealed. - ECF No. 148-4: parties directed to file a motion by September 3, 2026 or it will be unsealed.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.