VLSI Technology LLC v. Intel Corporation
- Beth Freeman
- 5:17-cv-05671
- U.S. District Court · Northern District of California
- 4
In VLSI Technology LLC v. Intel Corporation, Judge Freeman granted one sealing motion and denied four others concerning materials in Intel’s summary-judgment filing.
Intel Corporation and the parties whose materials were at issue: VLSI Technology LLC, Microsoft Corporation, Fortress Investment Group LLC, Finjan Software, Inc., Finjan, Inc., and NXP B.V.
What happened
VLSI Technology LLC v. Intel Corporation involved five motions by Intel about whether materials from other parties should be sealed in connection with Intel’s summary-judgment filing. The affected parties were VLSI, Microsoft, Fortress, Finjan, and NXP.
The court applied a strong presumption that court records should be publicly accessible. It found that Finjan showed compelling reasons to protect confidential business information and that its request was narrowly limited. The other four parties did not provide proposed sealing or redaction requests.
Judge Beth Labson Freeman granted Intel’s motion concerning Finjan’s material and denied the motions concerning VLSI, Microsoft, Fortress, and NXP. Intel was ordered to file public redacted versions of the relevant filings and exhibits under the agreed schedule.
The detailed version
- VLSI Technology LLC v. Intel Corporation · No. 5:17-cv-05671
- Beth Freeman
- Sept. 18, 2023
Background
Intel filed five administrative motions asking the court to consider sealing material belonging to other parties in connection with Intel’s omnibus motion for summary judgment and its exhibits. The materials concerned VLSI Technology LLC, Microsoft Corporation, Fortress Investment Group LLC, Finjan Software, Inc. and Finjan, Inc. (collectively, “Finjan”), and NXP B.V.
Intel certified that it served the non-parties associated with three of the motions, and that NXP was served by VLSI. Finjan was the only party that filed a response. Finjan asked the court to redact two lines from Intel’s summary-judgment motion.
Legal standard
The court explained that judicial records generally carry a strong presumption of public access. For records more than tangentially related to the merits of a case, a party seeking to seal them must show “compelling reasons” that outweigh public access. For records unrelated or only tangentially related to the merits, the lower “good cause” standard applies. That standard requires a specific showing of likely harm; broad, unsupported allegations are insufficient.
Rulings
The court found compelling reasons to seal the highlighted portions sought by Finjan because they contained sensitive financial and business information, including confidential agreement terms concerning compensation, licensed patents, and other substantive provisions. The court also found that Finjan’s request was narrowly tailored. The court therefore granted Administrative Motion No. 584.
VLSI, Microsoft, Fortress, and NXP did not respond with proposed sealing requests or redactions. The court therefore denied Administrative Motions Nos. 581, 582, 583, and 585. The order’s introductory explanation describes the remaining motions as denied without prejudice, while the numbered order states that each of those four motions is “DENIED.”
Intel was ordered to file public redacted versions of the corresponding motion and exhibits, subject to this order, the court’s other orders, and the parties’ agreed schedule.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.