Sequoia Benefits & Insurance Services LLC v. Costantini
- William Alsup
- 3:20-cv-08089
- U.S. District Court · Northern District of California
- 2
In Sequoia Benefits v. Costantini, Judge Alsup denied Sequoia’s motion to reconsider refusing to seal Exhibit G.
Sequoia Benefits & Insurance Services, LLC’s request to restrict public access to Exhibit G was denied; the opinion identifies Luciano Costantini and other defendants as having been heard on the request.
What happened
Sequoia Benefits & Insurance Services, LLC v. Costantini concerns Sequoia’s request to keep Exhibit G from public view in a trade-secret case. The court had previously denied that request but conditionally allowed another document, Exhibit 120, to be sealed.
Sequoia argued that Exhibit G was similar to Exhibit 120 and should also be sealed. Sequoia described Exhibit G as showing client identities and some account information, while Exhibit 120 included additional details such as billing dates, invoicing methods, contact email addresses, and pricing information.
The court ruled that Sequoia had not shown a serious error or supplied new facts that justified changing the earlier decision. Judge Alsup denied Sequoia’s motion for reconsideration.
The detailed version
- Sequoia Benefits & Insurance Services LLC v. Costantini · No. 3:20-cv-08089
- William Alsup
- June 2, 2021
Background
Sequoia Benefits & Insurance Services, LLC, identified in the opinion as a trade-secret claimant, sought permission to ask the court to reconsider an earlier order denying its request to file Exhibit G under seal. Sealing means restricting public access to a court filing. The earlier order had also conditionally granted Sequoia’s request to seal Exhibit 120 because it allegedly contained the trade secrets at issue.
Arguments and analysis
Sequoia argued that similarities between Exhibit G and Exhibit 120 justified sealing Exhibit G as well. Sequoia had described Exhibit G as showing its client identities and certain account information. It had described Exhibit 120 as showing confidential client identities, billing effective dates, invoicing methods, dates showing when clients became Sequoia clients, contact email addresses, and pricing information.
The court applied the standard for reconsideration, which generally requires newly discovered evidence, clear error, or an intervening change in controlling law. The court found that Sequoia had not shown that the earlier order failed to consider important facts or decisive legal arguments. It also found that Sequoia had not provided facts sufficient to justify reconsideration or sealing Exhibit G. The court rejected Sequoia’s attempt to replace its earlier inadequate justification for sealing Exhibit G with the justification that had supported sealing the other document.
Ruling
The court denied Sequoia’s partial motion for reconsideration. The opinion does not state that the court changed the earlier decision regarding Exhibit G.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.