Logicease Solutions Inc. v. Softworks AI, LLC

Background

LogicEase Solutions Inc. asked to file a redacted complaint and to seal entirely a contract and amendments attached as exhibits. The stated bases were that the contracts contained a confidentiality provision and that Softworks AI had asked LogicEase to file the complaint and exhibits under seal.

Court’s analysis

The court explained that federal court records are subject to a strong presumption of public access. A party seeking to redact or seal a filed document must provide a particularized showing of good cause for restricting access to records related to a non-dispositive motion, and potentially a stronger “compelling reason” showing for records related to dispositive motions or the merits. The court did not decide which standard applied because the requests failed under either standard.

The proposed complaint redactions concerned what the court described as purely generic information, including the date of a contract and a one-sentence request for attorney’s fees. The parties sought to seal the contract exhibits in their entirety even though they appeared to be a standard software license agreement and amendments. The court said the parties had not identified any sensitive commercial or proprietary information. It also concluded that the requests did not comply with the district’s local rules, which require a showing that the material is privileged, a trade secret, or otherwise legally protectable, and require sealing requests to be narrowly tailored.

Disposition

The court denied the redaction and sealing requests in toto. It ordered LogicEase to re-file the complaint and exhibits without redactions by June 22, 2021.