Lone Star Silicon Innovations LLC v. United Microelectronics Corporation

Background

The parties sought to file under seal portions of briefing and exhibits related to defendants’ motion to dismiss for lack of standing. The materials included passages discussing a patent transfer agreement between Advanced Micro Devices, Inc. and Lone Star, the agreement itself, and an amendment to it.

Lone Star stated that the agreement contained a confidentiality provision. The parties also asserted that disclosure could cause competitive harm because competitors could use the agreement’s terms and conditions.

Court’s analysis

The court explained that judicial records are subject to a strong presumption of public access. Because the materials were connected to a motion that could dispose of claims, sealing required compelling reasons supported by specific factual findings that outweighed the policies favoring disclosure.

The court found the parties’ assertions insufficient. It described the claimed competitive harm and possible use by competitors as conclusory and speculative. It also stated that confidentiality designations and agreements between the parties do not by themselves make documents sealable under Civil Local Rule 79-5(b) and (d). In addition, the requests covered large portions of the briefing and were not narrowly tailored as required by Rule 79-5(b). Finally, the court noted that the patent transfer agreement had already been unsealed and publicly disclosed, except for Advanced Micro Devices’ bank-account information, and that the agreement’s terms had already been discussed publicly in another order.

Disposition

The court denied the administrative motions to file under seal. It ordered the parties to file unredacted versions of the documents on the public docket by October 4, 2019, at noon.