People.ai, Inc. v. SetSail Technologies, Inc.
- William Alsup
- 3:20-cv-09148
- U.S. District Court · Northern District of California
- 3
In People.ai v. SetSail, Judge Alsup denied five sealing motions and granted SetSail’s motion to seal financial information.
People.ai, SetSail, and the public’s access to the specified court filings.
What happened
People.ai, Inc. v. SetSail Technologies, Inc. involved competing requests to keep parts of court filings from public view.
People.ai conditionally filed documents under seal because SetSail had labeled material confidential. SetSail also asked to seal portions of a filing and a supporting declaration concerning its financial information.
Judge William Alsup denied People.ai’s five sealing motions because SetSail did not provide the required justification. He granted SetSail’s motion after finding that its proposed redactions were narrow and protected sensitive financial information.
The detailed version
- People.ai, Inc. v. SetSail Technologies, Inc. · No. 3:20-cv-09148
- William Alsup
- Feb. 9, 2022
Background
This omnibus order resolved all pending motions to seal. The court explained that court records connected more than indirectly to the merits of a case generally may be sealed only for “compelling reasons.” Records connected only indirectly to the merits may be sealed upon a showing of “good cause.” Under the district’s local rules, a sealing request must be narrowly tailored, and the supporting declaration must specifically explain why the identified material is sealable. A confidentiality designation or protective order alone is not enough.
People.ai’s Motions
People.ai conditionally filed under seal documents and portions of documents from five filings containing material that SetSail had designated confidential: People.ai’s motion for leave to file a second amended complaint, the reply supporting that motion, the second amended complaint, and People.ai’s motion for summary judgment. SetSail did not file supporting declarations establishing that the documents or portions were sealable, as required by the local rules.
For material filed with the second amended complaint, People.ai’s supporting declaration stated that the material was People.ai’s confidential information, which the court said appeared to be a drafting error. The court added that, even if the statement was not an error, People.ai had not actually justified sealing the material. The court therefore DENIED the motions to file the material in Docket Nos. 60, 62, 67, 73, and 112 under seal.
SetSail’s Motion and Disposition
SetSail moved to seal portions of its opposition to People.ai’s motion to enlarge the time to respond to SetSail’s motion for judgment on the pleadings, along with the supporting declaration of Haggai Levi. After reviewing the accompanying declaration of Brun, the court found that the proposed redactions were narrowly tailored and disclosed confidential, sensitive information about SetSail’s financials whose public disclosure would harm SetSail competitively. The court therefore GRANTED SetSail’s motion.
The court ordered the movants to file public versions of the affected documents in full compliance with the order by March 4, 2022, at noon. Judge William Alsup signed the order on February 9, 2022.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.