DiscoverOrg Data, LLC v. Bitnine Global, Inc.
- Lucy Koh
- 5:19-cv-08098
- U.S. District Court · Northern District of California
- 5
In DiscoverOrg Data v. Bitnine Global, Judge Koh granted DiscoverOrg’s motion to seal limited default-judgment filings containing sensitive pricing and contract information.
DiscoverOrg Data, LLC, whose limited redactions were approved; the sealed material concerns its pricing and contracts with third parties.
What happened
DiscoverOrg Data, LLC sued Bitnine Global, Inc. over trade secret, copyright, and related claims, and asked to seal limited portions of its motion for default judgment and supporting declarations. The court considered only that sealing request.
The court said default-judgment materials are closely connected to the case’s merits, so DiscoverOrg had to show compelling reasons for sealing them. DiscoverOrg identified pricing and third-party contract information that was not publicly known and could harm its competitive position if disclosed.
The court found that potential competitive harm outweighed the public’s general right to inspect court records. Judge Koh granted DiscoverOrg’s motion to file the specified portions under seal.
The detailed version
- DiscoverOrg Data, LLC v. Bitnine Global, Inc. · No. 5:19-cv-08098
- Lucy Koh
- Nov. 6, 2020
Background
DiscoverOrg Data, LLC brought trade secret, copyright, and related claims against Bitnine Global, Inc. DiscoverOrg moved to file under seal certain portions of its motion for default judgment and supporting declarations.
Legal standard
Court records are generally presumed to be available to the public. Because a motion for default judgment is case-dispositive and more than tangentially related to the underlying claims, the court applied the “compelling reasons” standard. Under that standard, the party seeking sealing must provide specific reasons that outweigh the public’s interest in access to court records. The court also required the proposed redactions to be limited to material that is legally protectable, such as trade secrets or confidential commercial information.
Court’s analysis
DiscoverOrg proposed a limited number of redactions concerning its pricing and contracts with third parties. It argued that information about its database, pricing, and third-party contracts was not common knowledge and was sensitive competitive information because its business was developing and changing.
The court concluded that disclosure could cause competitive harm. It held that this harm was a compelling reason to seal the identified information and outweighed the general presumption of public access. The court also noted that the requested redactions were limited and specific rather than broad and categorical.
Disposition
The court GRANTED DiscoverOrg Data, LLC’s motion to file under seal portions of its motion for default judgment and supporting declarations. The order addressed the sealing request, not the underlying trade secret or copyright claims.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.