Teradata Corporation v. SAP SE
- William Orrick
- 3:18-cv-03670
- U.S. District Court · Northern District of California
- 2
In Teradata Corporation v. SAP SE, Magistrate Judge Spero granted limited sealing, denied other requests, and ordered a response about Exhibit 8.
Teradata and SAP, as well as public access to the exhibits filed in the case.
What happened
In Teradata Corporation v. SAP SE, Teradata asked to keep exhibits to a joint letter brief from the public record, relying partly on SAP’s confidentiality designations. SAP supported sealing some material.
The court found good reason to seal narrowly identified portions of Exhibit 2 but not the rest. It was not persuaded that sealing all of Exhibit 8 was properly limited and ordered Teradata to identify the sensitive portions. Because SAP did not seek to seal Exhibit 9, the court denied sealing for that exhibit.
Chief Magistrate Judge Joseph C. Spero granted Teradata’s request for the specified portions of Exhibit 2, denied it for the remainder of Exhibit 2 and all of Exhibit 9, and ordered Teradata to explain by October 8, 2020 why its request for Exhibit 8 should not be denied.
The detailed version
- Teradata Corporation v. SAP SE · No. 3:18-cv-03670
- William Orrick
- Oct. 1, 2020
Background
Teradata Corporation, Teradata US, Inc., and Teradata Operations, Inc. moved to file under seal exhibits to a joint letter brief. SAP SE, SAP of America, Inc., and SAP Labs, LLC filed a responsive declaration supporting sealing some of the material.
The court explained that federal filings generally require “compelling reasons” for sealing. For discovery documents filed with a motion that is not closely connected to the underlying claims, however, “good cause”—a showing sufficient to justify protecting confidential information—may be enough. The court also stated that sealing requests must be narrowly tailored, often through redactions instead of sealing entire documents.
Exhibit 2
Teradata sought to seal Exhibit 2 based on SAP’s confidentiality designation. SAP’s attorney, Tharan Gregory Lanier, identified portions on page 36 that should be sealed to protect technical details of SAP’s proprietary products. The court reviewed those portions and found good reason to seal them. Teradata’s motion was GRANTED as to those portions and DENIED as to the remainder of Exhibit 2. The court ordered Teradata to file a public version of Exhibit 2 by October 8, 2020, redacting only the portions identified in Lanier’s declaration.
Exhibit 8
Teradata sought to seal all of Exhibit 8, stating that it detailed trade secrets SAP allegedly misappropriated from Teradata and contained highly sensitive trade-secret information. The court found good cause to seal much of the exhibit’s technical details and internal product-development discussions. But the exhibit also contained SAP’s interrogatories, Teradata’s legal objections, and basic descriptions of Teradata’s business model that did not appear to contain sensitive information. The court therefore found the request to seal the entire exhibit insufficiently narrow.
The court ORDERED TO SHOW CAUSE why Teradata’s motion to seal Exhibit 8 should not be denied. It ordered Teradata to respond by October 8, 2020, identifying the sensitive portions that warranted sealing. The opinion did not finally grant or deny the request for Exhibit 8.
Exhibit 9 and disposition
Teradata sought to seal Exhibit 9 based on SAP’s confidentiality designation. Lanier’s declaration stated that SAP did not seek to seal the exhibit. The court therefore DENIED Teradata’s motion as to Exhibit 9 and ordered Teradata to file Exhibit 9 unredacted in the public record by October 8, 2020.
Chief Magistrate Judge Joseph C. Spero issued the order on October 1, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.