Schulte v. LinkedIn Corporation
- Haywood Gilliam
- 4:22-cv-00237
- U.S. District Court · Northern District of California
- 4
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
In Schulte v. LinkedIn Corporation, Judge Gilliam granted in part and denied in part LinkedIn's motion to seal certain documents, finding some proposed redactions too broad.
Litigants and businesses in federal court who seek to keep court filings confidential — this ruling illustrates that courts in the Northern District of California will deny sealing requests that are overbroad or lack a specific, particularized showing of harm, even when no party opposes the motion.
What happened
In Schulte v. LinkedIn Corporation (No. 22-cv-00237-HSG, N.D. Cal.), LinkedIn filed an administrative motion asking the court to seal portions of its motion challenging a magistrate judge's discovery order, along with an exhibit attached to that motion. No opposition was filed. The court had to decide which, if any, of the proposed redactions were legally justified under the applicable standard for sealing court records.
Because the underlying motion concerned a non-dispositive pretrial discovery dispute, the court applied the lower 'good cause' standard rather than the stricter 'compelling reasons' standard. Under this standard, a party must make a particularized showing that specific harm will result from disclosure — broad or vague justifications are not enough. The court found that some of LinkedIn's proposed redactions covered only high-level, general descriptions of documents that did not reveal any sensitive business information, and therefore those redactions were not sufficiently narrow or justified. Other proposed redactions, as well as the entire exhibit, were found to legitimately protect information about business strengths and weaknesses, proprietary business and sales information, and employees' personal identifying information.
Judge Haywood S. Gilliam, Jr. granted in part and denied in part LinkedIn's motion to seal. The court ordered LinkedIn to file a publicly available, partially redacted version of its motion by September 10, 2026, keeping under seal only those portions that satisfied the good cause standard.
The detailed version
- Schulte v. LinkedIn Corporation · No. 4:22-cv-00237
- Haywood Gilliam
- Sept. 4, 2026
Background
This case is a civil action in the Northern District of California in which Kevin Schulte and other plaintiffs are suing LinkedIn Corporation. The opinion does not describe the underlying merits of the dispute. The ruling concerns only LinkedIn's administrative motion to seal documents filed in connection with its motion seeking relief from a non-dispositive pretrial discovery order issued by a magistrate judge.
The Motion to Seal
LinkedIn filed an administrative motion (Dkt. No. 247) to seal portions of its Motion for Relief from a Non-Dispositive Pretrial Order of a Magistrate Judge (Dkt. No. 246) and to seal in its entirety Exhibit 1 to that motion (Dkt. No. 246-1 / 247-3). No opposition was filed.
Legal Standard
The court explained that motions to seal court documents are generally governed by the 'compelling reasons' standard, which derives from the public's common-law right to inspect judicial records. However, records attached to motions that are only 'tangentially related to the underlying cause of action' are held to the lower 'good cause' standard under Federal Rule of Civil Procedure 26(c).
Under the 'good cause' standard, the moving party must make a particularized showing that specific prejudice or harm will result from disclosure. Broad, conclusory, or generalized assertions are insufficient.
The court applied the good cause standard here because the underlying motion addresses a non-dispositive pretrial deposition discovery order, which is tangentially related to the underlying cause of action.
Ruling on Each Document
Motion for Relief (Dkt. Nos. 246 / 247-2) — Granted in Part and Denied in Part
The court found that certain proposed redactions lacked good cause because they covered only high-level, general descriptions of underlying documents that did not themselves reveal any of LinkedIn's 'strengths and areas for improvement' or details about proprietary business activities. Specific portions denied sealing included: the parenthetical at page 4, line 19 related to document -173967; the first clause of the first sentence of footnote 6 on page 4; a parenthetical in footnote 6 related to -00188009; page 5, line 1; page 5, line 11; and parentheticals in footnote 7 related to documents -00155549 and -211971.
Conversely, the court found good cause to seal other portions because they contained information about business strengths and weaknesses, proprietary business activities, or other sensitive commercial information. Portions granted sealing included: the parenthetical at pages 4:18–19 related to document -00174719; the second clause of the first sentence of footnote 6; pages 5:3–5; and the footnote 7 parenthetical related to document -191393.
Exhibit 1 (Dkt. Nos. 246-1 / 247-3) — Granted in Full
The court granted sealing of Exhibit 1 in its entirety, finding good cause because it contains information related to business strengths and areas for improvement, proprietary business and sales or licensing information, and employees' personally identifiable information.
Order
The court granted in part and denied in part the motion to seal (Dkt. No. 247). LinkedIn was ordered to file a publicly available, partially redacted version of the Motion for Relief from a Non-Dispositive Pretrial Order of a Magistrate Judge (Dkt. No. 246) on the public docket by September 10, 2026, consistent with the court's rulings on which portions may remain sealed.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.