Align Technology, Inc. v. SmileDirectClub, LLC
- Edward Chen
- 3:23-cv-00023
- U.S. District Court · Northern District of California
- 4
In Align Technology v. SmileDirectClub, Judge Chen granted in part and denied in part motions to seal, requiring a redacted complaint.
Align Technology, Inc., the defendants collectively identified as SDC, and members of the public seeking access to the complaint and attached arbitration decision.
What happened
Align Technology, Inc. and the defendants known collectively as SDC asked the Northern District of California to seal information connected to Align’s complaint, including an arbitration decision.
The court provisionally sealed the arbitration decision in full but did not decide which parts ultimately deserved protection. It rejected SDC’s argument that public access could spread false or misleading information, finding that embarrassment, possible marketplace harm, or further litigation was not enough to justify sealing.
In Align Technology, Inc. v. SmileDirectClub, LLC, et al., Judge Edward Chen denied most requests to seal complaint passages but granted them in part for specific payment and numerical information. Align had to file a publicly redacted complaint within three court days.
The detailed version
- Align Technology, Inc. v. SmileDirectClub, LLC · No. 3:23-cv-00023
- Edward Chen
- Feb. 9, 2023
Background
The court considered two motions to seal information related to Align Technology, Inc.’s complaint: one filed by Align and one filed by the defendants, whom the opinion collectively calls “SDC.” Align had initially agreed that the information should be sealed but later took a neutral position, leaving SDC to argue for sealing. SDC submitted a supplemental brief identifying the information it wanted sealed and its reasons.
Court’s analysis
Because the requests concerned a complaint, the court applied the “compelling reasons” standard for sealing court records. The court provisionally sealed the arbitration decision attached as Exhibit 3 to the complaint in its entirety. It emphasized that this was not a final determination that every part of the decision deserved sealing and explained that the entire decision was not needed to understand Align’s complaint.
SDC argued that portions of the arbitration decision were untrue or misleading, lacked broader context, and could be used by competitors to disparage SDC’s business model or harm the company in the marketplace. The court rejected that argument. It found that disclosure was unlikely to result in improper uses such as scandalous or libelous purposes, and noted that SDC could explain publicly why it believed the arbitration decision was wrong. The court also relied on the principle that embarrassment, exposure to further litigation, or similar concerns alone do not establish compelling reasons to seal records.
Ruling
The court granted in part and denied in part the sealing requests. It denied the requests for portions of paragraphs 9, 96, 99, 101, 102, 103, 170, 171, 172, and 173. For paragraph 97, it granted in part and denied in part the request: the amount of the payment could be sealed, but the remaining information could not. For paragraph 98, it likewise granted in part and denied in part the request: the last sentence containing specific numbers could be sealed, but the rest could not.
The court ordered Align to file a publicly redacted version of the complaint consistent with those rulings within three court days. The order disposed of Docket Nos. 2 and 26.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.