X One, Inc. v. Uber Technologies, Inc.
- Lucy Koh
- 5:16-cv-06050
- U.S. District Court · Northern District of California
- 5
In X One v. Uber, Judge Koh granted in part and denied in part X One’s motion to seal a filing about reconsideration and patent-claim reduction.
X One, Inc. must file the document according to the court’s partial sealing ruling. Uber Technologies, Inc. obtained sealing for specified information about the technical operation of its applications, while the public will have access to the information the court ordered left unsealed.
What happened
In X One, Inc. v. Uber Technologies, Inc., X One asked to seal its request for reconsideration, further objections, and notice of a second patent-claim reduction. Uber submitted a declaration supporting the request.
The court treated the filing as unrelated to the case’s merits because it concerned a case-narrowing order. It therefore applied the lower standard requiring a showing of good cause. The court found that much of the information described the technical operation of Uber’s applications and that disclosure could harm Uber’s competitive position.
The court granted in part and denied in part the motion to seal. It granted sealing for the listed portions on page 2, lines 15–16 and 27–28, and page 3, lines 5–6, but denied sealing for page 2, lines 20–21 because that information was already publicly disclosed. Judge Lucy H. Koh ordered X One to file the document as directed by October 22, 2019.
The detailed version
- X One, Inc. v. Uber Technologies, Inc. · No. 5:16-cv-06050
- Lucy Koh
- Oct. 16, 2019
Background
X One, Inc. filed an administrative motion to seal its Request for Reconsideration, Further Objections and Notice of Second Patent Claim Reduction. The filing concerned the court’s case-narrowing order. The court had previously denied the sealing motion, but explained that the denial was made in error because it had not considered Uber Technologies, Inc.’s supporting declaration.
Legal standard
Court records are generally presumed to be open to the public. For records connected to motions that could dispose of claims, a party generally must show “compelling reasons” to overcome that presumption. For records attached to non-dispositive motions that are unrelated or only tangentially related to the merits, the party need show only “good cause,” a lower standard.
The court agreed that X One’s filing was non-dispositive because it concerned the case-narrowing order rather than the merits of the case. The court therefore applied the good-cause standard. It found that information about the functionality and operation of Uber’s applications could reveal trade secrets and harm Uber’s competitive standing in the ride-sharing industry. The court also emphasized that sealing requests must be narrowly tailored and supported by the required materials under the court’s local rules.
Ruling
The court granted in part and denied in part the administrative motion to file under seal. For the Request for Reconsideration, Further Objections and Notice of Second Patent Claim Reduction, the court ruled as follows:
- Page 2, lines 15–16: GRANTED. - Page 2, lines 20–21: DENIED, because the information Uber sought to seal was publicly disclosed in the preceding sentence, including the statement that Uber receives maps from multiple third-party providers. - Page 2, lines 27–28: GRANTED. - Page 3, lines 5–6: GRANTED. - Page 3, lines 5–6: GRANTED.
The court ordered X One to file the document in accordance with the order by October 22, 2019. Judge Lucy H. Koh signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.