Calhoun v. Google LLC

Background

The court considered the parties' joint submission concerning Google's request to seal portions of the transcript of an April 29, 2021 discovery hearing.

Legal standard

Court records are generally presumed to be accessible to the public. The court explained that the standard for sealing depends on how the records were used. Records related more than tangentially to the merits of a case require “compelling reasons” for secrecy. Records related only tangentially to the merits, including records submitted in connection with discovery matters, may be sealed upon a showing of “good cause” under Federal Rule of Civil Procedure 26(c). A party seeking to seal records must also follow the court's local procedures.

Ruling

The court held that the good-cause standard applied because the information was submitted in connection with a discovery-related motion rather than a motion concerning the merits of the case. It granted the request as to the specified redacted portions of the April 29, 2021 discovery-hearing transcript. The court found the redactions narrowly tailored to protect confidential information concerning Google's internal systems and operations, including the identifiers and cookies Google uses internally, the proprietary functions of those systems, the types of data logs Google maintains, and which logs are linked to a user's Google Account.