Davis v. Pinterest, Inc.
- Haywood Gilliam
- 4:19-cv-07650
- U.S. District Court · Northern District of California
- 9
In Davis v. Pinterest, Judge Gilliam granted in part and denied in part four sealing motions and denied two others.
Harold Davis, Pinterest, Inc., Pinterest employees and third parties whose personal identifying information appeared in the materials, and members of the public seeking access to the court records.
What happened
In Davis v. Pinterest, Inc., the parties asked the court to keep portions of documents related to their summary-judgment and evidence-related motions from public view. The court applied a strong presumption that court records should be accessible and required specific reasons for sealing.
The court denied Docket Nos. 177 and 190. It granted in part and denied in part Docket Nos. 149, 154, 158, and 172. The court allowed sealing for some proprietary Pinterest policies and systems, personal identifying information, and certain information about Pinterest’s machine-learning methods, but required public versions of documents for which sealing was denied.
Judge Haywood S. Gilliam, Jr. ordered the parties to file those public versions within seven days of the order. This order addressed access to court records, not the underlying claims or defenses in the case.
The detailed version
- Davis v. Pinterest, Inc. · No. 4:19-cv-07650
- Haywood Gilliam
- Sept. 26, 2022
Background
The parties filed administrative motions to seal portions of documents submitted with their motions for summary judgment and motions in limine. The court considered Docket Nos. 149, 154, 158, 172, 177, and 190.
Legal standard
For records connected to dispositive motions, such as summary-judgment motions, the court applied the “compelling reasons” standard. That standard starts with a strong presumption that judicial records should be open to the public. The party seeking sealing had to identify specific reasons that outweighed the public’s interest in disclosure and had to request sealing narrowly.
The court explained that a confidentiality designation or a protective order, by itself, does not establish that material may be sealed. For records connected to nondispositive motions, the lower “good cause” standard applies, requiring a particularized showing of specific harm from disclosure.
Discussion
The court found that some materials contained proprietary information about Pinterest’s repeat-infringer and takedown policies under the Digital Millennium Copyright Act. Public disclosure could lead to third-party abuse or competitive harm. Other materials contained personal identifying information, including phone numbers and email addresses of Pinterest employees and third parties, implicating those individuals’ privacy interests.
The court also found that certain materials contained confidential information about Pinterest’s notification system, training information, and details about Pinterest’s Digital Millennium Copyright Act policies. In one set of materials, the court allowed sealing of specified pages containing personal identifying information and specified materials describing Pinterest’s proprietary methods for its machine-learning algorithms.
Disposition
The court denied Docket Nos. 177 and 190. It granted in part and denied in part Docket Nos. 149, 154, 158, and 172. Documents covered by granted sealing requests would remain under seal. The court directed the parties to file public versions of documents for which sealing was denied within seven days from the date of the order.
Judge Haywood S. Gilliam, Jr. signed the order. The opinion does not decide the parties’ underlying claims or motions for summary judgment.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.