Reflex Media, Inc. v. SuccessfulMatch.com

Background

SuccessfulMatch.com and Successful Match Canada, referred to together as Successful Match, and plaintiffs Clover8 Investments and Reflex Media, Inc. asked the court to seal documents filed in connection with discovery disputes. The requests concerned docket numbers 54, 56, 70, and 74, and the documents and excerpts listed in the court's attached chart.

Legal standard

The court applied the strong presumption that judicial records are open to the public. A party seeking to seal a court record must show compelling reasons supported by specific factual findings that outweigh the public's interest in access. General claims of possible competitive or commercial harm are insufficient. A confidentiality designation under a protective order, by itself, also does not justify sealing.

Court's analysis

The court stated that most of the requests failed because no designating party filed a statement or declaration supporting sealing, as required by the local rule. For the remaining requests, plaintiffs made only general assertions that documents contained confidential information about Reflex Media's company structure, operations, profits, revenue, marketing, advertising spending, profit margins, and cash flows. Plaintiffs did not explain specifically how disclosure would cause competitive harm or how a competitor could use the information to obtain an unfair advantage.

The attached chart separately lists each request and marks it denied. These included highlighted portions of plaintiffs' discovery-dispute filings, exhibits supporting plaintiffs' motion for sanctions, and portions or exhibits from defendants' opposition to that motion. The court also noted that plaintiffs had not asked to seal one item in their response.

Disposition

The court denied all sealing requests. It directed the parties to file unredacted versions of the documents by July 31, 2023. Judge James Donato entered the order on July 24, 2023.