Richter v. Oracle America, Inc.
- Beth Freeman
- 5:22-cv-04795
- U.S. District Court · Northern District of California
- 3
In Richter v. Oracle America, Inc., Judge Freeman granted Richter’s motion to seal specified paragraphs containing personal financial information and ordered redacted filings.
Haoning Richter and the declarants whose personal financial information appeared in the specified paragraphs; Oracle America, Inc. and the public docket are affected by the limited sealing order.
What happened
In Richter v. Oracle America, Inc., Haoning Richter asked to seal portions of two declarations supporting her opposition to Oracle America, Inc.’s motion for attorneys’ fees. She said the portions contained personal financial information.
The court applied a good-cause standard because the declarations concerned a motion about attorneys’ fees, which was only indirectly related to the case’s merits. It found that protecting the financial information justified sealing the specified paragraphs and that the request was narrowly limited.
Judge Beth Labson Freeman granted the motion as to paragraphs 3–5 of Gautam Dutta’s declaration and paragraphs 4–7 of Haoning Richter’s declaration. The court ordered Richter to file redacted versions publicly by September 6, 2023.
The detailed version
- Richter v. Oracle America, Inc. · No. 5:22-cv-04795
- Beth Freeman
- Aug. 30, 2023
Background
Plaintiff Haoning Richter filed an administrative motion to seal two declarations supporting her opposition to Defendant Oracle America, Inc.’s motion for attorneys’ fees. Richter identified personal financial information as the reason for requesting sealing. The motion was ECF No. 69.
The court noted that filings connected to a motion for attorneys’ fees are subject to the less demanding “good cause” standard because fee motions are only tangentially related to the merits of the underlying case. The court also discussed Civil Local Rule 79-5, which requires a party seeking sealing to explain the need for confidentiality, identify the harm from disclosure, explain why less restrictive alternatives would not suffice, provide evidentiary support when necessary, and narrowly tailor the request.
Court’s Analysis
Richter’s filings and proposed order appeared to request sealing of the entire declarations, even though her motion identified only particular portions as sealable. The court construed the request as seeking to seal only the paragraphs listed in the table on pages 3 and 4 of the motion.
The court found good cause to seal those portions because they contained confidential personal financial information. It concluded that protecting the declarants’ privacy interests and preventing harm outweighed the public’s interest in access to those portions of the filings. The court also found the request narrowly tailored when limited to the identified paragraphs.
Disposition
The court granted Richter’s motion to file under seal as to the specified paragraphs:
- ECF No. 69-3, the declaration of Gautam Dutta: paragraphs 3–5, containing confidential personal financial information whose disclosure would cause harm. - ECF No. 69-4, the declaration of Haoning Richter: paragraphs 4–7, containing confidential personal financial information whose disclosure would cause harm.
Judge Beth Labson Freeman directed Richter to file redacted versions of the declarations on the public docket no later than September 6, 2023. This order addressed sealing only; the opinion does not decide the motion for attorneys’ fees.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.