In re Lyft Inc. Securities Litigation

Background

The parties filed administrative motions asking the court to keep documents connected to the plaintiff’s motion for class certification from public view. The requests concerned documents and portions of filings submitted by both sides, including a deposition transcript, Lyft’s roadshow document, investor declarations, portions of declarations, and exhibits that had been designated confidential.

Legal standard

Because class certification was more than tangentially related to the underlying case, the court applied the “compelling reasons” standard. Under that standard, the party seeking secrecy must identify compelling reasons supported by specific facts that outweigh the strong presumption of public access to judicial records. The request also must be narrowly tailored to cover only material that is privileged, a trade secret, or otherwise legally entitled to protection. The court noted that records connected only loosely to the case may instead be governed by the lower “good cause” standard, but it did not apply that standard here.

Reasons for denying the requests

The court found that the defendants had not provided sufficient justification or narrowly tailored their requests. A confidentiality designation, standing alone, did not make a document eligible for sealing. The court also rejected generalized assertions that competitors could use information to Lyft’s detriment. Requests to seal entire exhibits containing investor declarations were overbroad because the declarations largely contained high-level statements about the investors’ knowledge.

The court also denied the plaintiff’s request to seal certain exhibits and related references because the defendants’ counsel stated that the defendants did not seek confidential treatment for those exhibits. The opinion further states that the plaintiff did not seek to seal the deposition transcript.

Disposition

The court DENIED the parties’ administrative motions to file under seal. It DIRECTED the parties to file public versions of all documents for which sealing was denied within seven days. The parties may also file new sealing motions within seven days that comply with the court’s requirements. Any new request must identify the public and provisionally sealed document docket numbers, the document name, the specific portions sought to be sealed, and specific supporting reasons with citations to declarations and legal authority.