Katz-Lacabe v. Oracle America, Inc.
- Richard Seeborg
- 3:22-cv-04792
- U.S. District Court · Northern District of California
- 3
In Katz-Lacabe v. Oracle America, Inc., Judge Seeborg denied plaintiffs’ motion to seal most of two reports.
The plaintiffs, whose proposed redactions were denied, and Oracle America, Inc., whose reports were at issue. The court permitted the plaintiffs to submit narrower redactions.
What happened
In Katz-Lacabe v. Oracle America, Inc., the plaintiffs asked to keep most of two reports from Oracle, called Offline Access Request Response Reports, out of the public record. They filed the request after the court had previously told them to seek much narrower redactions.
The court said the plaintiffs did not adequately explain why generic terms such as “Household,” “Ad Occurrence,” “Gender,” “Ethnicity,” and “Language Preference” would reveal private information. The court noted that specific values or details might deserve protection, but the category names alone did not.
Judge Seeborg denied the motion and also denied the request for oral argument. The plaintiffs may submit a more limited redaction request within two weeks; otherwise, they must refile the complaint using the redactions specified in the earlier order.
The detailed version
- Katz-Lacabe v. Oracle America, Inc. · No. 3:22-cv-04792
- Richard Seeborg
- Sept. 5, 2023
Background
Plaintiffs filed an administrative motion under the Northern District of California’s local rules asking to seal portions of their First Amended Class Action Complaint. The motion concerned two Offline Access Request Response Reports, which plaintiffs received from Oracle America, Inc. The reports were 49 and 32 pages long, and plaintiffs sought to redact nearly all of both documents.
The motion followed an earlier order directing plaintiffs to propose a “far more limited set of redactions.” Plaintiffs argued that the reports contained information about financial accounts, transactional activity, interests, habits, activities, and other details about their lives. Oracle had not objected to sealing the documents in an earlier filing, according to the opinion.
Court’s Analysis
The court concluded that plaintiffs’ proposed redactions were still too broad. Plaintiffs did not explain how generalized categories or associations appearing throughout the reports would cause a privacy injury. The court identified terms such as “Household” and “Ad Occurrence” as generic descriptions that did not reveal plaintiffs’ personal interests, queries, or habits.
The court also distinguished between demographic category names and the information associated with those categories. It stated that specific values or details might be private, but that merely listing categories such as “Gender,” “Ethnicity,” or “Language Preference” did not reveal the information Oracle actually collected. The court therefore found that plaintiffs’ claim that they had limited the proposed redactions to their personal information was not supported by the submission.
Disposition
The court denied plaintiffs’ motion to seal the two reports. It also denied plaintiffs’ request for oral argument. The court gave plaintiffs leave to file a more limited redaction request within two weeks of the order. If they did not do so, the court directed them to refile the complaint using the redactions specified in its earlier order. The order was signed by Chief United States District Judge Richard Seeborg on September 5, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.