MasterObjects, Inc. v. Amazon.com, Inc.

Background

This omnibus order addressed all pending motions to seal connected to completed motion practice. The filings concerned disputes over infringement contentions, requests to strike or supplement those contentions, claim construction, counsel disqualification, discovery and alleged spoliation, Amazon’s motion concerning MasterObjects’ alleged unclean hands, terminating sanctions, and protective-order information from earlier litigation.

Legal standard

The court explained that the public generally has a right to access court filings. Materials more than tangentially related to the merits may be sealed only for “compelling reasons,” while materials only tangentially related to the merits may be sealed upon a showing of “good cause.” Under the district’s local rule, a sealing request must identify the private or public interests supporting secrecy, the injury that would result from disclosure, and why a less restrictive alternative would not work. Redactions must be narrowly tailored, and supporting declarations must explain specifically why the information remains sealable. A protective order or confidentiality designation alone was not enough.

Rulings on the sealing requests

The court granted limited sealing for information describing Amazon’s confidential software architecture, source code, server configurations, autocomplete technology, and specific code files when disclosure could cause competitive harm or reveal trade secrets. It also granted limited sealing for specific terms in licensing agreements involving MasterObjects and a nonparty licensee, and for sensitive terms in a settlement agreement between MasterObjects and eBay. In those circumstances, the court found the requests narrowly tailored and the public interest in the information relatively low.

The court denied or partially denied many other requests. It rejected redactions covering general technical explanations, methods of producing documents, claim-construction arguments, generic descriptions of software, and other material for which the parties provided no specific justification. It also denied sealing when a party whose information was involved did not seek continued confidentiality.

For filings related to Amazon’s motion concerning MasterObjects’ alleged unclean hands, the court noted that its order denying that motion had already been placed on the public docket in full. The court therefore denied sealing for material already disclosed there and found that the parties’ broad descriptions of settlement discussions and older versions of Amazon’s autocomplete system did not establish a current, specific risk of competitive harm. The court denied without prejudice requests concerning an Amazon autocomplete architecture memo and a search-completion design wiki entry, allowing Amazon fourteen days to submit revised requests identifying any information that might still be confidential.

Disposition

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 November 7, 2022. Judge William Alsup signed the order on September 5, 2022.