Patel v. Alphabet Inc.

Background

Raj Patel filed a renewed motion asking the court to keep under seal his Fourth Amended Complaint, all earlier versions of his complaint, and his Motion to Reconsider. The court had previously denied Patel’s earlier sealing motion without prejudice because he had not shown compelling reasons to seal all or part of his pleadings and because the request was not narrowly tailored.

Legal standard

Courts generally recognize a public right to inspect and copy judicial records. Because a complaint is more than tangentially related to the merits of a case, the court applied the “compelling reasons” standard. Under that standard, sealing requires a strong justification. The court also noted that Northern District of California Civil Local Rule 79-5 requires a sealing request to identify the private or public interests supporting secrecy, explain the injury that would result from public disclosure, address why less restrictive alternatives are inadequate, provide evidentiary support when necessary, and narrowly limit the proposed sealing.

Arguments and ruling

Patel argued that the proposed redactions contained trade secrets and confidential information that could prejudice him. The court found that none of the material Patel sought to seal was confidential, that Patel had not alleged any trade secrets, and that he had not explained how he would be prejudiced or why the alleged prejudice satisfied the compelling-reasons standard.

Judge Beth Labson Freeman denied Patel’s Motion to File Under Seal. The court directed Patel to file his Fourth Amended Complaint on the public docket or amend it to exclude matters he chose not to file publicly no later than September 11, 2023.