Blockchain Innovation, LLC v. Franklin Resources, Inc.
- Thomas Hixson
- 3:21-cv-08787
- U.S. District Court · Northern District of California
- 3
In Blockchain Innovation v. Franklin Resources, Judge Gilliam denied one sealing motion as moot and denied another, ordering public versions.
The parties to Blockchain Innovation, LLC v. Franklin Resources, Inc., particularly the defendants and any parties that designated the disputed materials as confidential.
What happened
Blockchain Innovation, LLC v. Franklin Resources, Inc. involved two requests to keep documents related to defendants’ motions to dismiss from public view.
The court said documents connected to a motion that could decide claims generally require strong, specific reasons for secrecy. It found that the requests did not meet that standard because the materials had only been labeled confidential and the designating party did not provide the required declaration.
Judge Gilliam denied the first motion as moot and denied the second motion. The documents tied to the first motion could remain under seal, but the parties had seven days to file public versions of documents covered by the denied second motion.
The detailed version
- Blockchain Innovation, LLC v. Franklin Resources, Inc. · No. 3:21-cv-08787
- Thomas Hixson
- Sept. 29, 2022
Background
The court considered two administrative motions asking to seal materials connected to defendants’ motions to dismiss. Docket No. 41 concerned materials associated with motions to dismiss that became moot after Blockchain Innovation filed a first amended complaint. Docket No. 60 concerned materials associated with defendants’ motions to dismiss the first amended complaint.
Legal standard
The court explained that judicial records attached to a motion that could resolve claims are subject to the “compelling reasons” standard. Under that standard, the party seeking secrecy must identify specific reasons that outweigh the public’s strong interest in access to court records. Materials attached to motions that do not resolve claims are subject to the lower “good cause” standard, which requires a particularized showing of specific harm. The court applied the compelling-reasons standard to Docket No. 60 because it involved documents related to dispositive motions.
Discussion
The court denied Docket No. 41 as moot because the related motions to dismiss had been terminated as moot after the first amended complaint was filed. Since the court had not considered those motions, it also would not consider their associated documents; those documents would remain under seal, and the parties were excused from filing public versions of them.
For Docket No. 60, defendants sought to seal portions of briefing, part of an exhibit supporting a request for judicial notice, and another exhibit. The materials included asset-purchase agreements underlying Blockchain Innovation’s claims. The request sought to seal the agreements completely and redact portions of other filings that quoted them. The only stated basis was that the documents had been designated confidential. The party that designated the documents did not file the declaration required by Civil Local Rule 79-5(f)(3), and the court explained that a confidentiality designation or protective order alone does not establish that documents may be sealed.
Disposition
The court DENIED Docket No. 41 as moot and DENIED Docket No. 60. It directed the parties to file public versions of all documents for which sealing had been denied within seven days of the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.