Flextronics International USA, Inc. v. Murata Manufacturing Co., Ltd.
- Edward Davila
- 5:19-cv-00078
- U.S. District Court · Northern District of California
- 3
In Flextronics v. Murata, Judge Davila denied Flextronics’s motion to seal complaint portions without prejudice because the supporting reasons were too general.
Flextronics may renew its sealing request, while the defendant must provide specific supporting documentation for any renewed request; the public’s access to the complaint portions remains protected by the court’s presumption of disclosure.
What happened
Flextronics International USA, Inc. v. Murata Manufacturing Co., Ltd. concerned Flextronics’s request to keep portions of its second amended complaint from public view. The request involved information related to allegations of price-fixing and other anticompetitive conduct.
The court said judicial records are generally open to the public. To seal these records, the supporting party had to provide specific facts showing compelling reasons for confidentiality. The court found that labeling information “Highly Confidential” under a protective order and making general claims about trade secrets, customers, and business information were not enough.
Judge Edward J. Davila denied the sealing motion without prejudice. Flextronics may consult the applicable local rule and renew the motion with sufficient supporting reasons within 10 days, and the defendant must provide adequate documentation supporting sealing.
The detailed version
- Flextronics International USA, Inc. v. Murata Manufacturing Co., Ltd. · No. 5:19-cv-00078
- Edward Davila
- Nov. 21, 2019
Background
Flextronics filed an administrative motion asking to seal portions of its second amended complaint. The opinion states that the defendant was the designating party and filed a declaration supporting sealing, while no party objected to Flextronics’s motion.
Legal standard
The court explained that the public generally has a right to inspect judicial records. Because the requested sealing concerned material more than tangentially related to the underlying claims, the party seeking confidentiality had to show “compelling reasons” supported by specific facts that outweighed the presumption of public access. General claims of harm, embarrassment, or confidentiality were insufficient. The court also stated that a designation under a protective order, by itself, does not establish that material may be sealed.
Court’s analysis
The court found the sealing request overbroad and unsupported. The material generally concerned allegations about defendants’ price-fixing conduct. The court found that the supporting declaration’s generalized statement that the material contained trade secrets and confidential business information about customers and business dealings did not establish a compelling reason for sealing.
The court denied sealing for the listed portions of the complaint, including paragraphs 16, 417, 235, and 237–70. It described those materials as general allegations concerning anticompetitive practices, defendants, conspiracy, and external communications. For the material covering paragraphs 237–70, the court found no trade secrets or customer information that had not already been disclosed in the unredacted complaint.
Disposition
Judge Edward J. Davila denied the motion to seal at ECF 68 without prejudice. The court instructed Flextronics to consult Civil Local Rule 79-5(e)(2) and stated that the moving party could renew the motion with sufficient reasons in supporting declarations no later than 10 days after the order was filed. The order specifically stated that the defendant must submit adequate documentation showing a compelling reason for sealing and that generalized confidentiality allegations were insufficient.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.