People.ai, Inc. v. SetSail Technologies, Inc.

Background

This order addressed motions to seal filed in connection with SetSail Technologies, Inc.’s motion for attorney’s fees. SetSail sought to seal portions of its fee motion and supporting declaration. People.ai, Inc. conditionally filed under seal material supporting its opposition to SetSail’s fee motion.

Legal standard

The court explained that court records are generally open to the public. Materials more than loosely connected to the merits of a case may be sealed only for “compelling reasons,” while materials only loosely connected to the merits may be sealed on a showing of “good cause.” A sealing request must identify the private or public interests supporting secrecy, explain the harm from disclosure, and show why a less restrictive option would not work. The requested redactions must be limited to material that can properly be sealed. Declarations must explain the alleged harm specifically rather than rely on general statements or a confidentiality agreement.

Rulings

For SetSail’s motion for attorney’s fees, the court granted the request to seal highlighted portions of SetSail’s motion because they contained sensitive, specific information whose disclosure could cause competitive harm.

The court denied the request to seal paragraph four of the Levi Declaration. SetSail had not explained how disclosure of its nonspecific description of the litigation’s effect on its Series A financing could cause competitive harm or otherwise provided enough justification for secrecy. The court granted the request as to the declaration’s remaining redactions because they concerned sensitive and confidential business information whose disclosure could cause competitive harm.

For People.ai’s opposition to SetSail’s fee motion, the court denied the sealing motion because SetSail had not filed a supporting declaration as required by the district’s local rule.

The court concluded that the administrative motions to seal were “GRANTED IN PART and DENIED IN PART.” It ordered the parties to refile the relevant documents in compliance with the order by May 31, 2022. Judge William Alsup signed the order.