Lyft, Inc. v. AGIS Software Development LLC

Background

Lyft filed administrative motions under Civil Local Rule 79-5(f), asking the court to decide whether materials designated confidential by AGIS Software should be filed under seal. The requests concerned documents Lyft submitted in support of its motion to compel discovery and compliance with the Local Patent Rules, and its motion for leave to file a first amended complaint. AGIS Software supported the sealing requests with declarations.

Legal standard

The court explained that judicial records are generally available to the public. Because the documents concerned a discovery motion and a motion to amend the complaint, the court applied the less demanding “good cause” standard for sealing. Civil Local Rule 79-5 also required a party seeking sealing to identify the specific material, explain the interests supporting secrecy and the harm that would result from disclosure, explain why a narrower alternative would not suffice, and provide evidentiary support when necessary.

Rulings

The court found that AGIS Software showed good cause to seal material containing sensitive business, financial, and licensing information.

- For ECF No. 75, Lyft’s motion to compel discovery and compliance with the Local Patent Rules, the court granted sealing for the specified highlighted portions. - For ECF No. 75-1, Exhibit 10, AGIS Software’s supplemental interrogatory responses, the court granted sealing for the portions identified as supported by AGIS Software’s declaration. It denied sealing as to all other portions because they lacked evidentiary support from a declaration. - For ECF No. 75-1, Exhibit 18, the March 22, 2022, deposition transcript of Thomas Meriam, the court granted sealing of the entire document. - For ECF No. 78, Lyft’s motion for leave to file a first amended complaint, the court granted sealing for the specified highlighted portions. - For ECF No. 78-1, Exhibit 1, the first amended complaint, the court granted sealing for some highlighted portions and denied sealing for other listed portions because they lacked evidentiary support from a declaration. - For ECF No. 78-1, Exhibit 7, AGIS Software’s supplemental interrogatory responses, the court granted sealing for the portions supported by the declaration and denied sealing as to all other portions for lack of evidentiary support. - For ECF No. 78-1, Exhibit 11, the March 22, 2022, deposition transcript of Thomas Meriam, the court granted sealing of the entire document.

Disposition

The court ordered that Lyft’s administrative motions to consider whether another party’s material should be sealed were granted in part. It also ordered Lyft to file newly redacted versions of ECF No. 75-1, Exhibit 10; ECF No. 78-1, Exhibit 1; and ECF No. 78-1, Exhibit 7, by April 13, 2022.