Snapkeys, LTD v. Google LLC
- Lucy Koh
- 5:19-cv-02658
- U.S. District Court · Northern District of California
- 7
In Snapkeys v. Google, Judge Koh granted in part and denied in part Google’s request to seal summary-judgment materials.
Google and Snapkeys; Google’s business partners and current and former employees whose information was at issue; and the public’s access to the court filings.
What happened
Snapkeys, Ltd. sued Google LLC for breach of contract and conversion. Google asked to keep portions of its summary-judgment motion and supporting declarations and exhibits from public view.
The court allowed Google to seal information about its smartwatch technology, confidential information about business partners, and employees’ personally identifying information. It denied Google’s request to seal documents that Snapkeys had labeled confidential because Snapkeys did not file the required declaration showing that the material was sealable.
In Snapkeys, Ltd. v. Google LLC, Judge Lucy H. Koh granted in part and denied in part Google’s sealing motion and ordered Google to refile its summary-judgment materials within seven days in accordance with the ruling.
The detailed version
- Snapkeys, LTD v. Google LLC · No. 5:19-cv-02658
- Lucy Koh
- May 14, 2021
Background
Snapkeys, Ltd. sued Google LLC for breach of contract and conversion. Google filed a motion for summary judgment, which is a request to resolve claims without a trial when the relevant facts are not genuinely disputed. Google separately asked to seal portions of that motion and portions of the declarations and exhibits supporting it.
Legal standard
Because the materials were connected to a dispositive motion—one that could resolve the case—the court applied the “compelling reasons” standard. Under that standard, the party seeking secrecy must show specific reasons strong enough to outweigh the public’s general right to inspect court records. The court also applied Civil Local Rule 79-5, which requires a narrowly tailored request and, when one party has designated material as confidential, a declaration establishing that the material is legally sealable.
Court’s analysis
The court granted Google’s request to seal confidential information about Google’s smartwatch technology because disclosure could cause competitive harm. It also granted the request to seal confidential information about Google’s business partners because disclosure could harm Google’s and its partners’ competitive standing.
The court granted Google’s request to seal personally identifying information— including email addresses and telephone numbers—of current and former Google employees. The court stated that this information was not relevant to the merits of Google’s summary-judgment motion and found compelling reasons to seal it.
Google also sought to seal documents that Snapkeys had designated confidential under the parties’ stipulated protective order, as well as references to those documents in Google’s summary-judgment motion. Under the local rule, Snapkeys had four days after Google filed the sealing motion to submit a declaration establishing that the material was sealable. Snapkeys had not filed that declaration by May 14, 2021. The court therefore denied Google’s request to seal those documents.
Disposition
Judge Lucy H. Koh granted in part and denied in part Google’s motion to file under seal. The court ordered Google to refile its summary-judgment motion and supporting exhibits within seven days, consistent with the court’s rulings.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.