Big Baboon, Inc. v. SAP America, Inc.

Background

Defendant SAP America, Inc. asked to file under seal documents related to its motion to compel discovery in aid of judgment. The requested documents contained confidential and sensitive financial information concerning Big Baboon, Inc.’s operations and liabilities, including account numbers, balance sheets, and copies of checks.

The opinion states that the court had previously granted summary judgment for the defendants and that the case was terminated on April 24, 2019. It also states that the motion to compel discovery in aid of judgment was granted in part and denied in part on June 5, 2020, without reference to the information SAP America sought to seal.

Legal Standard

Courts generally require “compelling reasons” to seal records connected to dispositive motions—motions that could resolve the case. Records connected to nondispositive motions—motions that do not decide the underlying case—are subject to the lower “good cause” standard. That standard requires a particularized showing that specific harm or prejudice would result from disclosure. Civil Local Rule 79-5 also requires the sealing request to be narrowly tailored to material that is privileged, a trade secret, or otherwise legally protected.

Court’s Analysis

Because the motion to compel discovery was not dispositive, the court applied the good-cause standard. The court determined that the documents disclosed confidential financial information and were unrelated to the public’s understanding of the judicial proceedings. It also found that the public interest in disclosure was minimal because the case and the discovery motion had been resolved.

Ruling

Judge Haywood S. Gilliam, Jr. granted Defendant SAP America, Inc.’s administrative motion to file under seal. The court stated that, under Civil Local Rule 79-5(f)(1), the documents would remain under seal.