Sonos, Inc. v. Google LLC
- William Alsup
- 3:21-cv-07559
- U.S. District Court · Northern District of California
- 4
In Sonos v. Google, Judge Alsup granted some sealing requests and denied others because Google did not adequately justify withholding information.
Sonos, Inc. and Google LLC, whose filings and exhibits were subject to the court’s sealing rulings, as well as the public’s access to those materials.
What happened
In Sonos, Inc. v. Google LLC, both parties asked the Northern District of California to seal materials connected to Sonos’s third amended complaint and Google’s answer.
The court denied requests involving general information about Google’s systems and other materials Google said it did not seek to seal. It granted requests covering confidential licensing negotiations, portions of an infringement chart, and references to confidential business negotiations and agreements.
Judge Alsup said the parties must refile the relevant documents in compliance with the order by May 31, 2023, at noon, and noted that the basis for sealing could change at trial or later.
The detailed version
- Sonos, Inc. v. Google LLC · No. 3:21-cv-07559
- William Alsup
- Feb. 24, 2023
Background
The order addressed pending motions to seal filed in connection with Sonos’s third amended complaint and Google’s answer. The court emphasized the strong public policy favoring open court records. It explained that materials more than tangentially related to the merits may be sealed only for “compelling reasons,” while materials unrelated or only tangentially related to the claims may be sealed upon a showing of “good cause.” The party seeking sealing must identify specific harm, explain why disclosure would cause injury, and show why a less restrictive alternative would not be sufficient. Requests must also be narrowly tailored, and supporting declarations must provide particular explanations rather than boilerplate assertions.
Rulings on the sealing requests
- Dkt. 160-2, Exhibit 2: Denied. Google sought to seal general technical information about its systems and operations. The court found Google’s support overbroad and nonspecific. Google did not explain in particular how disclosure would cause competitive harm and relied on a generic assertion that competitors could use the information. - Dkt. 160-3, Exhibit 3: Denied. Google clarified that it did not seek to seal this material. - Dkt. 212-2, Exhibit CD to Sonos’s Third Amended Complaint: Granted. The material concerned confidential licensing negotiations, and public disclosure could cause Google competitive harm. - Dkt. 212-3, Exhibit CI: Granted. The material included portions of Sonos’s infringement contention chart, and public disclosure could cause Google competitive harm. - Dkt. 212-4, Exhibit CJ; Dkt. 212-5, Exhibit CK; and Dkt. 212-6, Exhibit CL: Granted. The court referred to the reasoning for Dkt. 212-3. - Dkt. 212-7, Exhibit CW: Denied. Google clarified that it did not seek to seal this material. - Dkts. 213-3 and 214-3, Exhibit CC: Granted. The material concerned confidential licensing negotiations, and public disclosure could cause Google competitive harm. - Dkts. 213-4 and 214-4, Exhibit CE: Granted. The court referred to the reasoning for Dkt. 214-4. - Dkts. 221-3 and 222-2, Google’s answer: Granted. The parties sought to seal references to confidential business negotiations and agreements, and public disclosure could harm both parties. - Dkts. 221-4 and 222-3, Exhibit 2; and Dkts. 221-5 and 222-4, Exhibit 3: Granted. The court referred to the reasoning for Dkt. 221-3. - Dkt. 221-6: The table refers to the entry for Dkt. 221-3 but does not separately display a different result for this item.
Effect of the order
The parties were directed to refile all relevant documents in full compliance with the order by May 31, 2023, at noon. The court warned that the sealing analysis could change at trial or otherwise. Judge William Alsup entered the order on February 24, 2023.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.