MasterObjects, Inc. v. Meta Platforms, Inc.

Background

This omnibus order addressed all remaining motions to seal and related exhibits. The filings concerned MasterObjects’ motion for sanctions, Meta’s motion to strike, Meta’s motion for summary judgment, Meta’s motion to exclude experts, and several miscellaneous filings.

The court explained that the public has a strong interest in access to court records. Materials more than tangentially related to the merits of a case may be sealed only upon a showing of compelling reasons. Materials only tangentially related to the merits may be sealed upon a lesser showing of good cause. Under the Northern District of California’s local rule, a sealing request must identify the legitimate interests supporting secrecy, the injury that would result from disclosure, and why a less restrictive alternative would not work. The request must also be narrowly tailored, and supporting declarations must explain specifically why the material remains sealable rather than relying on general confidentiality statements or protective orders.

Rulings on the Sealing Requests

For materials related to MasterObjects’ motion for sanctions, the court denied many of Meta’s requests. The court found that Meta’s explanations were broad and nonspecific, and that the requests covered information such as general descriptions of Meta’s Typeahead system, the number of source-code files produced in discovery, and ordinary computer-science terms. The court also denied requests covering deposition testimony, discovery responses, emails, and other high-level information because Meta did not adequately explain how disclosure would cause competitive harm. The court granted requests covering certain internal scheduling information, detailed technical documentation, internal notes, and related materials containing confidential information about Meta’s systems. One request concerning Meta’s opposition to the sanctions motion was granted in part and denied in part because the diagram on page seven could cause competitive harm, while the remainder did not meet the sealing standard.

For materials related to Meta’s motion to strike, the court granted some requests involving information about non-party licensees and denied the remaining requests. The court found that narrowly tailored information about agreements, identities, or other matters involving non-party licensees could cause competitive harm and had little public interest for purposes of the motion practice. It denied requests that were overbroad or supported only by boilerplate explanations, including requests covering legal argument, general information about Typeahead, and material where Meta asserted that source code was present even though the document contained none. Several requests concerning MasterObjects’ materials were granted, including certain information related to non-party licensees. Other requests were granted in part and denied in part when only specific names, file identifiers, source-code method names, or line numbers justified sealing.

For materials related to Meta’s motion for summary judgment, the court denied Meta’s request to seal its motion and denied requests involving expert reports, deposition testimony, briefing, and discovery responses when the information went to the heart of the case or concerned information that appeared publicly accessible. The court found that Meta’s explanations were often boilerplate and did not show how disclosure would cause competitive harm. The court ruled that the sealing request for one group of exhibits was moot because Meta had refiled those exhibits with a notice of errata to comply with the case-management order.

For materials related to Meta’s motion to exclude experts, the court granted the sealing request for the listed materials. The court stated that no ruling had been made on that motion before the litigation ended, so the public interest in those materials was minimal. The court also denied a miscellaneous sealing request concerning claim-construction issues because MasterObjects did not seek to keep the material confidential.

The court granted the requests concerning MasterObjects’ explanations and correspondence about sealing the names and agreements of non-party licensees. It found those requests narrowly tailored, found little public interest in the information for purposes of the sealing motions, and found that disclosure could harm MasterObjects and the non-party licensees competitively.

Disposition and Effect

The court concluded that the motions were granted in part and denied in part. Requests denied without prejudice could be revised to justify sealing information that might still be confidential within fourteen days of the order. All other documents had to be refiled in full compliance with the order by May 19, 2023, at 12:00 p.m. Judge William Alsup signed the order as a United States district judge.