Photonic Technologies Co., Ltd. v. Eliyan Corporation

Background

Photonic Technologies filed an administrative motion to seal portions of its complaint and accompanying exhibits. The company described the material as confidential business documents, including a development agreement concerning commercially sensitive technologies. It argued that public disclosure could harm it. Eliyan Corporation did not file a response.

Legal standard

The court explained that judicial records generally are presumed open to public inspection. Because the sealing request concerned a complaint that was more than tangentially related to the underlying claims, Photonic Technologies had to show compelling reasons that outweighed the public’s interest in access. The court also applied the Northern District of California’s requirements that sealing requests identify the interests supporting secrecy, the injury from disclosure, why less restrictive alternatives would not work, and only seal material narrowly identified as sealable.

Ruling

The court found compelling reasons to seal confidential business and technical information whose disclosure could harm Photonic Technologies’ competitive standing. It also found the request narrowly tailored. The court granted the motion as to the identified highlighted portions of the complaint and Exhibits 1 through 8, describing those materials as confidential business and technical information whose release could harm Photonic Technologies. The order granted the administrative motion to file under seal, ECF No. 2.