Independent Living Resource Center San Francisco v. Lyft, Inc.

Background

Both parties moved to file under seal portions of exhibits and briefing connected with a bench trial. The court treated the materials as more than tangentially related to the merits of the dispute, meaning that sealing required “compelling reasons.”

The court explained that Lyft had previously been allowed to keep some ride-data information confidential at the summary-judgment stage and argued that confidentiality was needed to prevent competitors from reverse-engineering pricing and algorithm features. But the trial focused on the cost of Lyft’s wheelchair-accessible-vehicle rides. Evidence about costs in other cities, Lyft’s efforts and ideas for reducing costs, and the feasibility of those efforts were central to evaluating the plaintiffs’ claims. The court therefore concluded that only the most sensitive information should remain sealed.

Rulings

The court held that compelling reasons supported narrowly tailored sealing requests and granted those requests to the extent specified in the order. It denied the requests to the extent the order required materials to be filed publicly. The order’s table identified the portions that could remain sealed, including specified portions of contracts, business materials, trial exhibits, and expert materials. For several documents, the court required the remainder to be filed publicly; for certain email-related exhibits, it allowed redaction of email addresses, phone numbers, and other contact information while requiring the remaining material to be public.

The plaintiffs’ request to seal portions of their request for judicial notice concerning mathematical-equation results and a Securities and Exchange Commission filing was denied without prejudice because the plaintiffs had not provided the supporting declaration required by the court’s local rules. The court also ordered that unredacted versions of documents required to be unsealed would not be filed for seven days, and gave Lyft seven days to show cause why it had not timely responded in support of sealing portions of two exhibits. Except for those two exhibits, revised materials were to be filed within twenty-one days of the order.

Effect of the Order

This was an order about public access to litigation materials, not a decision resolving the underlying claims. Judge William Alsup permitted limited sealing, required other information to be filed publicly, denied one plaintiffs’ request without prejudice, and required Lyft to explain its late response concerning two exhibits.