Doyle v. Galderma Laboratories, L.P.
- Thomas Hixson
- 3:19-cv-05678
- U.S. District Court · Northern District of California
- 4
In Doyle v. Galderma Laboratories, Judge Hixson granted and denied specific requests to seal exhibits and ordered redactions.
Bruce Doyle, Galderma, nonparty current and former employees whose personal information appeared in the documents, and members of the public seeking access to the court record.
What happened
Doyle v. Galderma Laboratories, L.P. concerned requests about whether documents filed in connection with a summary-judgment motion should be available to the public or kept private.
Galderma asked to seal records containing nonparty employees’ private personnel information and Galderma’s confidential business information. Doyle asked to file some of his own documents publicly and opposed keeping other documents sealed.
Judge Hixson granted Galderma’s requests for some exhibits, denied its requests for others, and ordered redactions. He granted Doyle’s request for two exhibits, kept four other exhibits under seal, and ordered public, redacted versions of three additional exhibits.
The detailed version
- Doyle v. Galderma Laboratories, L.P. · No. 3:19-cv-05678
- Thomas Hixson
- Apr. 27, 2021
Background
The court considered two administrative motions about filing documents under seal, meaning keeping them from the public record. Galderma sought to seal materials filed with its pending motion for summary judgment, or partial summary adjudication. Galderma cited nonparty employees’ private personnel records and its own confidential and proprietary business information. Doyle asked the court to allow certain documents supporting his opposition to be filed publicly.
Galderma’s motion
The court granted Galderma’s motion with respect to Exhibit C to the Flores Declaration. The exhibit was a performance-improvement plan concerning a nonparty Galderma employee. The court found that the employee’s privacy interest outweighed the public’s interest in access and that the document could not easily be redacted without leaving identifying information.
The court denied Galderma’s motion with respect to Exhibits G and H to the Flores Declaration. Those exhibits were separation letters concerning former Galderma employees. The court found that they could be further redacted with minimal effort. It ordered Galderma to redact the names, separation dates, and end dates of insurance coverage and file the redacted versions publicly by April 28, 2021.
The court granted Galderma’s motion as to Exhibits C, D, and F to the Curley Declaration. Those exhibits contained information about regional budgets, sales and marketing allocations, and sales targets and results for Galderma’s prescription-business sales organization.
Doyle’s motion
The court granted Doyle’s motion with respect to Exhibits 1 and 2 to the Doyle Declaration. These were Doyle’s own records of awards, raises, and bonuses and his 2018 performance review. The court ordered Doyle to file them publicly by April 28, 2021.
The court agreed with Galderma that Exhibits 1 through 4 to the Wallace Declaration contained confidential and proprietary business information, and that Exhibits 5 through 7 contained third parties’ full birthdates. It ordered Exhibits 1 through 4 to remain under seal and ordered Doyle to file public versions of Exhibits 5 through 7 by April 28, 2021, with the month and day of each birthdate redacted.
Disposition
The order resolved only the sealing requests; Galderma’s summary-judgment motion remained pending. Judge Thomas S. Hixson granted and denied the sealing requests as specified above and issued the related redaction and filing orders.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.