WeRide Corp. v. Huang

Background

The court considered administrative motions asking to file portions of judicial records under seal. The materials were connected to WeRide’s motion for leave to file a Second Amended Complaint, the Second Amended Complaint, Defendant Huang’s answer, WeRide’s motion to modify a preliminary injunction, WeRide’s motion to shorten time, and related declarations and exhibits. Confidentiality designations were made by ZZX, AllRide, Huang, and Wang, although the opinion states that Huang did not file supporting declarations for the sealing requests concerning the Second Amended Complaint, the motion for leave to amend, or the motion to modify the preliminary injunction.

Legal standard

The court explained that the public generally has a right to inspect and copy judicial records, and that a strong presumption favors public access. Because the records were more than tangentially related to the underlying lawsuit, the parties seeking secrecy had to show “compelling reasons” that outweighed public access. Specific factual support was required; a broad claim of harm, a confidentiality designation, or a protective order alone was insufficient.

Rulings

For Docket No. 209, the motion to seal portions of the Second Amended Complaint was denied in its entirety. The court found that the proposed sealed material concerned the relationships among Huang, ZZX, and ZKA and related to the allegations underlying the litigation. For Docket No. 216, the motion concerning WeRide’s motion for leave to file a Second Amended Complaint was denied as to Exhibit E, granted as to Exhibit I, page 32, lines 18 and 22, and otherwise denied.

For Docket No. 217, the court denied most requests to seal portions of WeRide’s motion to modify the preliminary injunction. The court granted the requests for pages 5:21-22 and 6:1; page 6:5-6; page 22:2; the limitations proposed for the Declaration of Dr. Matthew R. Walter in § 14 of Docket No. 172; pages 5:16-17 and 19-22 of the Declaration of Ryan S. Landes; and the limitations proposed for Landes Exhibits 4, 6, 11, and 53 in §§ 4, 5, 7, and 13, respectively, of Docket No. 172. Each of those grants was otherwise denied where the order expressly said “otherwise denied.” The court also granted the requests to seal Landes Exhibits 36 and 38 in full because the designating party showed a compelling reason. It denied the requests for the other listed portions and exhibits, including Landes Exhibits 5, 7-10, 12-30, 37, 39-42, and 56-59, except for the specific grants stated above.

The court denied without prejudice the requests to seal Landes Exhibits 33, 34, and 35. It ordered the parties to meet and confer so that WeRide would submit only relevant deposition excerpts and the designating parties would propose narrowly tailored redactions limited to material meeting the compelling-reasons standard. The parties could file amended motions concerning those exhibits within seven days of the order.

For Docket No. 218, the motion to shorten time was denied because the material involved the lawsuit’s underlying allegations and the designating parties had not shown a compelling interest outweighing public access. For Docket Nos. 184, 186, 189, 199, 258, and 303, the court denied the motions without prejudice because they did not comply with local rules requiring, among other things, a Microsoft Word version of the proposed order and a table identifying each document or portion sought to be sealed. The parties could file compliant motions within seven days, subject to the court’s prior sealing rulings and specific page-and-line citations.

Effect of the order

This order addressed public access to court filings and did not decide the underlying claims or the motion to modify the preliminary injunction. Material covered by the court’s grants could remain sealed subject to the stated limitations, while most other requested material was not approved for sealing. The requests denied without prejudice could be renewed in compliance with the order.