Burzdak v. Universal Screen Arts, Inc.
- Edward Chen
- 3:21-cv-02148
- U.S. District Court · Northern District of California
- 2
In Burzdak v. Universal Screen Arts, Inc., Judge Chen granted a motion to seal outdated settlement figures after finding good cause.
Universal Screen Arts, Inc., Karen Burzdak, the class members referred to in the settlement agreements, and members of the public seeking access to the settlement figures.
What happened
In Burzdak v. Universal Screen Arts, Inc., Universal Screen Arts asked to keep certain settlement figures secret. The figures concerned renewal fees charged to class members and the share plaintiffs would have received under an earlier settlement agreement.
Universal argued that revealing the figures could harm its business by exposing revenue, profit margins, and commercial strategies. Plaintiff Karen Burzdak opposed sealing, arguing that the figures related to the case’s merits and that the public and class members had strong interests in seeing them.
The court found that an amended settlement agreement made the figures outdated and irrelevant. Judge Edward Chen ruled that the figures were like documents unrelated to a decision on the merits and that Universal had shown good cause for sealing them. The court granted the motion to seal.
The detailed version
- Burzdak v. Universal Screen Arts, Inc. · No. 3:21-cv-02148
- Edward Chen
- Sept. 1, 2023
Background
Plaintiff Karen Burzdak filed an administrative motion asking the court to consider whether materials submitted by another party should be sealed. Universal Screen Arts, Inc. sought to seal the total renewal fees charged to class members under the original settlement agreement and the percentage of that amount that plaintiffs would have received if the original agreement had taken effect.
Universal argued that the figures were confidential and highly sensitive information about its revenue from VIP memberships. It said disclosure could cause competitive harm because competitors could use the information to assess its margins, commercial strategies, or similar product features. Burzdak opposed sealing, arguing that the figures were connected to the merits of the case and that the public and class members had strong interests in them.
Court’s Analysis
The parties had filed an amended settlement agreement containing new figures. Because of that amendment, the court found that the figures from the original agreement were no longer relevant to the matter and that class members no longer had an interest in them. Although the figures were attached to a dispositive motion, the court concluded that they had no bearing on resolving the dispute on the merits and were more like materials from a non-dispositive motion.
For information connected to a non-dispositive motion, the court applied a requirement that the party seeking secrecy make a particularized showing of good cause. The court found that Universal had made that showing.
Disposition
The court granted the motion to seal and stated that the order disposed of Docket No. 86.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.