Carnegie Mellon University v. LSI Corporation

Background

Both sides filed multiple motions to seal records involving discovery letters, claim construction, and briefs, declarations, and exhibits related to LSI’s motion for partial summary judgment. The court described the requested sealing as covering a large volume of records that ordinarily would be available to the public.

Legal standards

The court emphasized the strong presumption that court records are open to the public. Under the standards discussed in the order, a party seeking to seal material connected to a non-dispositive motion must make a particularized showing of good cause. A request involving a dispositive motion, such as summary judgment, requires specific facts establishing compelling reasons for sealing. The court also cited the district’s local rule requiring sealing requests to identify material that is privileged, a trade secret, or otherwise legally protectable, and to limit the request to only that material.

Court’s analysis

The court found that the parties frequently used unsupported and conclusory descriptions such as “commercially sensitive,” “proprietary,” or “confidential.” The parties generally did not explain how public disclosure could cause harm, such as giving a competitor an unfair advantage. The court also found that the requests often sought to seal documents wholesale rather than narrowly identifying protectable portions.

As an example, the court discussed LSI’s request to redact two agreements that supported its implied-license defense. The agreements were at least two decades old, and neither side explained what harm public access might cause at that time. The court said that a party’s designation of documents as confidential under a protective order did not itself justify sealing them.

Ruling and directives

The court said it could order everything placed on the public docket but instead gave the parties another opportunity to submit well-supported requests for a discrete number of records. That opportunity did not extend to evidence cited in the court’s partial summary-judgment order, because the court determined that the parties had not established compelling reasons to seal that evidence. The court also determined that good cause had not been established for the non-dispositive discovery-letter filing. It directed the parties to file unredacted copies of those materials by October 2, 2020.

For other materials, the parties could file one consolidated motion to seal after meeting and conferring about disputes. The order required detailed factual support, a joint declaration identifying any disagreements, a proposed order in a specified table format, and a binder containing the proposed redactions. Those materials were due by October 9, 2020. If no renewed motion was filed, the parties had to file unredacted copies of the previously submitted materials publicly by October 16, 2020. The court warned that it could restrict or bar future sealing motions if the parties again failed to follow the governing standards, local rules, or court orders.

The text provided does not state a separate express grant or denial for every sealing motion identified by docket number; it instead gives the directives and deadlines described above.