In re Lyft Inc. Securities Litigation

Background

The court considered four administrative motions to seal materials related to three matters: Plaintiff’s motion for relief from a magistrate judge’s discovery order, Defendants’ motion for judgment on the pleadings, and Plaintiff’s motion for class certification.

Legal standards

For records attached to dispositive motions—motions that could resolve claims—the court applied the “compelling reasons” standard. That standard requires the party seeking secrecy to identify specific reasons that outweigh the public’s strong presumption of access to court records. For records attached to nondispositive motions, the court applied the lower “good cause” standard, which requires a particularized showing of specific harm or prejudice from disclosure.

The court explained that merely labeling information confidential, or asserting generally that disclosure could cause competitive harm, is not enough. Confidential business information and trade secrets may support sealing when disclosure could harm a party’s competitive position.

Rulings

The court granted the motion identified as docket number 167. That motion concerned excerpts from Plaintiff’s motion for relief from the magistrate judge’s discovery order and a proposed order. The excerpts referred to materials that had already been ordered sealed, and the court found good cause to seal them.

The court denied the motion identified as docket number 184 and denied the motion identified as docket number 187. Those motions sought to seal portions of filings concerning Defendants’ motion for judgment on the pleadings, including statistical information allegedly derived from confidential rider reports. The court found that Defendants had not shown a compelling reason overcoming the presumption of public access. The court noted that the statistics did not reveal individual riders or incidents and did not provide operational information beyond the total number of alleged sexual assaults, which was relevant to the case.

The court granted the motion identified as docket number 189. It allowed sealing of portions of rider-acquisition and rider-turnover statistics that competitors could use to Defendants’ disadvantage, as well as pages containing an investor’s detailed financial analysis, investment strategies, and research techniques. The court found these narrow redactions protected confidential proprietary information that could cause competitive harm if disclosed.

Disposition

The court granted the motion to seal as to docket numbers 167 and 189 and denied it as to docket numbers 184 and 187. It directed the parties to file revised public versions of documents for which sealing was denied within seven days. Documents covered by the granted motions remained under seal.