Core Optical Technologies, LLC v. Juniper Networks, Inc.

Background

Core Optical Technologies moved to seal portions of documents filed with its reply supporting a motion for leave to file an amended complaint. Juniper Networks identified portions that it said disclosed confidential aspects of its products, customer and business information, and the identities of its suppliers. Juniper stated that disclosure could violate contractual obligations to customers and harm its competitive position.

Legal standard

The court explained that when a motion is more than tangentially related to the merits of a case, a party seeking to seal documents must show “compelling reasons.” The court noted that district courts had applied different standards to motions for leave to amend pleadings. It assumed, without deciding, that the more demanding compelling-reasons standard applied here.

Ruling

The court concluded that Juniper had identified compelling reasons to seal the specific portions described in its counsel’s declaration. The court found that disclosure of those portions might harm Juniper’s competitive standing. Because Juniper’s request was narrower than the materials Core had originally designated, the court granted Core’s motion to seal only in part.

The court ordered Core to file redacted versions of Exhibit B and Exhibit J to its reply within seven days. The order did not extend sealing beyond the specific portions identified by Juniper in the declaration.