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

Background

The court had previously denied without prejudice a motion to seal two documents because Amazon’s requests were overbroad. The court gave Amazon 14 days to submit narrower requests supporting any information that remained confidential. Amazon timely renewed its request for one document: the declaration of Trevor Smedley, submitted in connection with Amazon’s summary-judgment motion. The declaration concerns source code that Amazon made available for inspection of its autocomplete technology for digital searches.

Sealing standard

The court explained that the public generally has a strong interest in access to court records. 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.” The court also noted that possible trade-secret infringement and harm to a litigant’s competitive position can support sealing.

Court’s reasoning

Amazon limited its request to source-code file names, class names, method names, file paths, and line numbers. It argued that public disclosure could cause competitive harm and that there was no legitimate public interest in the names and folder structures themselves. The court found minimal public interest in those items for purposes of the motion practice. It also found that the greater public interest in understanding how the autocomplete technology works was satisfied by Smedley’s descriptions of the roles of the files, classes, and methods and their relationships, which Amazon no longer sought to seal. The court found Amazon’s request adequately tailored, while noting that the analysis could differ if similar material were filed in another context.

Disposition

The court granted Amazon’s renewed motion to seal. It ordered Amazon to file the document in compliance with this order, and other documents in compliance with the earlier omnibus order, no later than April 10, 2023, at 12:00 p.m.