Calhoun v. Google LLC
- Yvonne Rogers
- 4:20-cv-05146
- U.S. District Court · Northern District of California
- 2
In Calhoun v. Google LLC, Judge Van Keulen granted Google’s motion to seal specified portions of a discovery letter brief about technical data-log information.
Google and members of the public seeking access to the identified portions of the court filing.
What happened
In Calhoun v. Google LLC, Google asked the court to seal portions of a joint discovery letter brief concerning Google’s motion for a protective order.
The court applied the lower “good cause” standard because the information was submitted in connection with a discovery-related motion rather than a motion addressing the case’s merits. The court noted that its conclusion could differ under another standard or in another context.
Judge Van Keulen granted the request for the identified redacted portions. The court found that the redactions were narrowly tailored to protect confidential technical information about Google’s data logs, including their type, contents, number, size, sampling method, and analysis service.
The detailed version
- Calhoun v. Google LLC · No. 4:20-cv-05146
- Yvonne Rogers
- Apr. 5, 2021
Background
Google filed an administrative motion to seal portions of the parties’ April 1, 2021 joint discovery letter brief. The brief concerned a dispute about Google’s motion for a protective order.
Legal Standard
Court records are generally presumed to be open to public inspection. The court explained that the standard for sealing depends on how the records are being used. The stricter “compelling reasons” standard applies to records connected more than tangentially to the underlying claims. The lower “good cause” standard under Federal Rule of Civil Procedure 26(c) applies to records that are not related, or are only tangentially related, to the merits.
The court held that the good-cause standard applied because the requested sealing concerned information submitted with a discovery-related motion. It also noted that a different standard or context could produce a different result.
Ruling
The court granted Google’s motion as to the redacted portions of the joint letter brief at pages 3:8–9, 4:20–22, 4:27–28, 5:23–25, 7:7–8, 7:14, 7:16–19, 7:23–24, 7:27–28, and 8:1–2. It found the redactions narrowly tailored to protect confidential technical information regarding various types of data logs maintained by Google, including the logs’ type, contents, number, size, sampling method, and analysis service.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.