Miller v. RP On-Site, LLC
- Lucy Koh
- 5:19-cv-02114
- U.S. District Court · Northern District of California
- 5
In Miller v. RP On-Site, LLC, Judge Koh granted RP On-Site’s renewed motion to seal specified portions of class-certification filings.
RP On-Site, LLC and the parties’ class-certification filings; specified portions of those filings will be kept from public access under the sealing order.
What happened
Miller v. RP On-Site, LLC concerned the defendant’s renewed request to keep portions of the parties’ class-certification filings from public view. The request covered parts of both the defendant’s opposition and the plaintiff’s motion.
The court applied a requirement that the defendant show strong reasons for sealing records because class-certification materials relate closely to the underlying claims. It found that the requested material contained proprietary business information whose disclosure could harm the defendant’s competitive position. The court also noted that the plaintiff had not filed a renewed request to seal by the deadline and therefore had given up any request to seal those filings.
Judge Lucy Koh granted the defendant’s renewed motion and authorized sealing the specific portions listed in the order, including portions of the parties’ memoranda and declarations.
The detailed version
- Miller v. RP On-Site, LLC · No. 5:19-cv-02114
- Lucy Koh
- Jan. 8, 2021
Background
RP On-Site, LLC filed a renewed administrative motion to seal portions of the parties’ briefing concerning the plaintiff’s motion for class certification. The requested materials included portions of the plaintiff’s memorandum, the declaration of James M. Treglio, the declaration of Manjit Sohal, and RP On-Site’s opposition memorandum.
The court had previously denied the defendant’s first sealing motion without prejudice because it did not comply with Civil Local Rule 79-5 and used the wrong legal standard. The court directed the parties to file a renewed motion that complied with the local rule and applied the “compelling reasons” standard. The opinion states that the plaintiff did not file a renewed sealing motion by the deadline, so the plaintiff waived any request to seal the class-certification briefing.
Legal standard
Court records are generally presumed to be open to public inspection. Because class-certification motions are closely connected to the factual and legal issues in the underlying claims, the court applied the “compelling reasons” standard. Under that standard, sealing may be justified when disclosure could, among other things, reveal trade secrets or business information that could harm a party’s competitive standing.
The local rule also required the sealing request to identify only material that was legally protectable, provide a supporting declaration, submit a narrowly tailored proposed order listing the material in table form, and provide unredacted documents showing the portions proposed for sealing.
Court’s reasoning
The court found that the renewed motion corrected the defects in the earlier motion. It applied the compelling-reasons standard, included a declaration stating that the material was sealable, supplied a table identifying the requested material, and attached unredacted documents highlighting the proposed redactions.
Sohal, identified in the opinion as RP On-Site’s Senior Director of Product Management, stated that the information was proprietary, gave RP On-Site a competitive advantage, and could disadvantage the company if released to competitors. The court concluded that the requested information was business information that could harm RP On-Site’s competitive standing if disclosed.
Disposition
The court granted RP On-Site, LLC’s renewed motion to seal. The order authorized sealing the specific portions identified in its table, including listed portions of the plaintiff’s class-certification memorandum, the Treglio declaration and its exhibits, the Sohal declaration, and RP On-Site’s opposition memorandum.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.