VLSI Technology LLC v. Intel Corporation

Background

VLSI Technology LLC filed an administrative motion asking to seal portions of two exhibits supporting its motion for summary judgment on Intel Corporation’s license defense and on invalidity based on estoppel from inter partes review proceedings. The documents concerned patent infringement and invalidity.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. Because the materials were connected to a motion for summary judgment and were more than tangentially related to the merits of the case, VLSI had to show “compelling reasons” to keep the identified material sealed. That standard requires specific reasons showing that disclosure would cause harm; broad, unsupported claims are not enough.

Court’s analysis

VLSI argued that the material contained confidential business information whose disclosure could cause competitive harm. The information included the legal rights and liabilities of VLSI’s members, business and investment strategies, management structure, asset capitalization, corporate governance, and business decision-making. The court found compelling reasons to seal the identified portions because they contained highly confidential and proprietary business information, and disclosure could cause significant competitive and business harms to VLSI. The court also noted that information in part of one highlighted paragraph was irrelevant to an issue in the case.

The order identified portions of Exhibit 2, an excerpt from VLSI Technology LLC’s 2016 limited liability company agreement, and Exhibit 26, an excerpt from its second amended and restated limited liability company agreement. The order granted sealing of the highlighted portions identified by their Bates numbers.

Disposition

Judge Beth Labson Freeman ordered that VLSI’s motion to seal at ECF No. 587 was GRANTED.