DSS Technology Management, Inc. v. Apple, Inc.

Background

The court considered 25 administrative motions asking to file portions of documents under seal. The documents were connected to the parties’ motions for partial summary judgment, motions concerning expert testimony, motions in limine, and Apple’s motion for permission to file an amended answer.

Legal standard

For documents connected to dispositive motions—motions that could resolve claims—the court generally applies a “compelling reasons” standard. Under that standard, the party seeking to seal information must identify compelling reasons supported by specific facts that outweigh the public’s strong presumption of access to judicial records. Documents connected to nondispositive motions—motions that do not resolve the underlying claims—are generally subject to the lower “good cause” standard, which requires a particularized showing of specific harm from disclosure.

Court’s analysis

The court found that the parties satisfied the applicable standards. Supporting declarations stated that the documents contained confidential business information, third-party information, licensing information, financial information, and nonpublic technical descriptions of the parties’ and third parties’ products. The court determined that this information was proprietary and confidential.

The court also noted that it had not relied on the documents involved in the sealing requests. The parties had stipulated to a final judgment of noninfringement, which the court granted, so the court would not rule on the underlying motions. As a result, the documents were unrelated to the public’s understanding of the judicial proceedings, and the public interest in disclosure was minimal.

Ruling

Judge Haywood S. Gilliam, Jr. granted the parties’ administrative motions to file under seal. Under Civil Local Rule 79-5(f)(1), the documents covered by the granted motions will remain under seal.