Stemmelin v. Matterport, Inc.
- William Alsup
- 3:20-cv-04168
- U.S. District Court · Northern District of California
- 7
In Stemmelin v. Matterport, Inc., Judge Alsup granted in part and denied in part motions to seal materials filed with class-certification papers.
John Stemmelin, Matterport, Inc., the other defendants identified in the caption, and members of the public seeking access to the court filings.
What happened
In Stemmelin v. Matterport, Inc., John Stemmelin and Matterport addressed whether documents filed with Stemmelin’s motion for class certification should remain sealed. The court emphasized the public’s strong right to access court records, especially records closely connected to the case’s merits.
The court denied sealing for many board minutes, presentations, and other materials because Matterport’s explanations were too general or did not show current competitive harm. It granted sealing for two documents containing sensitive business information about an internal project proposal and an internal sales summit. It also denied sealing for additional class-certification materials because Matterport did not provide the required supporting declaration, and denied sealing for the identified reply materials. Overall, the court granted in part and denied in part the administrative motions to seal.
Judge William Alsup ordered the parties to refile all relevant documents in compliance with the order by June 2, 2022.
The detailed version
- Stemmelin v. Matterport, Inc. · No. 3:20-cv-04168
- William Alsup
- May 5, 2022
Background
This order addressed administrative motions to seal documents filed in connection with John Stemmelin’s motion for class certification. The documents included board minutes, board presentations, internal emails, and other materials submitted by Stemmelin or Matterport.
Legal standard
The court explained that court records are generally open to the public. Documents more than tangentially related to the merits of a case may be sealed only for “compelling reasons.” Documents only tangentially related to the merits may be sealed upon a showing of “good cause.”
The court also stated that a sealing request must identify the private or public interests supporting secrecy, explain the injury that would result from disclosure, and explain why a less restrictive alternative would not suffice. The requested sealing must be narrowly limited to material that is actually sealable. Supporting declarations must provide specific explanations rather than boilerplate claims that information is confidential or proprietary.
Rulings on class-certification materials
Stemmelin did not seek to seal several documents filed in support of class certification. The court denied the sealing motion as to those documents.
The court denied sealing for numerous Matterport board minutes, including minutes from 2015 through 2018. Matterport described the materials generally as involving business updates, initiatives, sales and marketing, product development, budgets, financial information, and future plans. The court found that Matterport did not explain specifically what information remained confidential or how disclosure years later would cause current competitive harm.
The court also denied sealing for a document concerning a proposal related to Matterport’s MSP program. It found that the document involved material at the heart of the litigation and that Matterport’s generalized description of the document as containing proprietary strategies and plans did not show why disclosure would cause competitive harm. The court likewise denied sealing for a presentation titled “Launch Your Business with Matterport,” finding that Matterport had not provided specific reasons showing that disclosure would cause current competitive harm.
The court granted sealing for two documents: one containing confidential, sensitive business information about an internal project proposal, and another containing confidential, sensitive business information about an internal sales summit. The court found that disclosure of those documents could cause Matterport competitive harm.
The court denied sealing for a further group of materials filed in support of Stemmelin’s class-certification motion because Matterport did not file a supporting declaration establishing that the documents, or portions of them, were sealable under the local rules.
Rulings on reply materials
Stemmelin also conditionally filed documents under seal with his reply supporting class certification. Stemmelin did not seek to seal four identified documents, and the court denied the sealing motion as to those documents.
For the remaining materials, the court denied sealing for an internal email chain about lead generation for MSPs. Matterport argued that the communication concerned its Europe, Middle East, and Africa business and described it as containing confidential strategic plans and projections. The court found that this explanation was not sufficiently specific, that the document did not clearly appear limited to that region, and that possible embarrassment was not a sufficient reason to seal it.
Disposition
The administrative motions to seal were granted in part and denied in part. The parties were ordered to refile all relevant documents in full compliance with the order by June 2, 2022. Judge William Alsup signed the order on May 5, 2022.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.