Synkloud Technologies, LLC v. Adobe, Inc.
- William Alsup
- 3:20-cv-07760
- U.S. District Court · Northern District of California
- 6
In Synkloud Technologies v. Adobe, Judge Alsup denied Adobe’s motions to seal records from pre-settlement patent motions because they included public material.
Adobe Inc. and Synkloud Technologies, LLC, particularly the parties’ requests to keep case records from public view.
What happened
Synkloud Technologies, LLC v. Adobe Inc. is a patent dispute in which Adobe sought to seal records supporting several motions filed before the parties settled all claims.
The court found that many documents and excerpts contained information available to the public, including product screenshots and Adobe help pages. Adobe’s explanations that the materials were confidential or described product operations did not specifically explain why disclosure would cause harm.
Judge William Alsup denied Adobe’s sealing motions because Adobe had not narrowly identified sealable material or provided adequate reasons to overcome the public’s right of access to court records.
The detailed version
- Synkloud Technologies, LLC v. Adobe, Inc. · No. 3:20-cv-07760
- William Alsup
- Aug. 30, 2021
Background
This patent dispute involved Adobe Inc.’s motions to seal records supporting several motions filed before the parties settled all claims. The records included materials connected to the parties’ cross-motions for summary judgment and other motions.
Legal standard
The court explained that court records are generally open to the public. Records connected to a dispositive motion—a motion that may resolve claims or otherwise substantially address the merits—may be sealed only for compelling reasons supported by specific factual findings that outweigh the public’s interest in disclosure. Records connected with other, non-dispositive motions may be sealed upon a showing of good cause. Supporting declarations must explain specifically why each document or portion remains sealable; general or boilerplate claims of confidentiality are insufficient.
Court’s analysis
The court found that Adobe sought to seal many documents in their entirety even though they contained publicly available information. Examples included Synkloud’s amended patent-infringement contentions, screenshots of Adobe products and interfaces, publicly available Adobe help pages, and material from public websites.
The court acknowledged that other portions of the documents appeared to be nonpublic. But it found that the nonpublic material could not be separated from the public material based on Adobe’s submissions. The court rejected Adobe’s reliance on the parties’ protective order and its general statements that the records revealed confidential information about how Adobe’s products operated or concerned internal planning. Adobe did not explain how disclosure would cause potential harm or distinguish potentially sealable information from clearly public information.
The court also stated that it was not the district judge’s responsibility to sort through numerous documents filed under seal and select only the portions that might qualify for sealing. It found that Adobe had not properly tailored its requests, and noted a public interest in knowing how the patent owner had interpreted its patents in the case.
Disposition
The court denied Adobe’s sealing motions. The order did not rule on the underlying patent claims, which the opinion states had already been settled.
Judge
The order was signed by William Alsup, United States District Judge.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.