Carl Zeiss X-Ray Microscopy, Inc. v. Sigray, Inc.
- Edward Davila
- 5:21-cv-01129
- U.S. District Court · Northern District of California
- 5
In Carl Zeiss X-Ray Microscopy v. Sigray, Judge Demarchi granted sealing motions, protecting trade-secret and personnel materials while keeping other exhibits public.
Carl Zeiss and Sigray, whose confidential materials were treated differently for public access, as well as members of the public seeking access to the court filings.
What happened
Carl Zeiss X-Ray Microscopy, Inc. v. Sigray, Inc. involved requests to seal materials filed with Carl Zeiss’s motion for discovery sanctions. Carl Zeiss later withdrew that motion, but the sealing requests remained pending.
The court found good cause to seal Carl Zeiss documents containing claimed trade secrets and ordered the identified exhibits sealed in full. It also sealed one Sigray exhibit containing confidential employee information. Two other Sigray exhibits were not sealed and were ordered filed publicly.
Judge Virginia K. Demarchi granted the administrative sealing motions and terminated them. The ruling concerned access to filed materials, not the underlying discovery-sanctions dispute.
The detailed version
- Carl Zeiss X-Ray Microscopy, Inc. v. Sigray, Inc. · No. 5:21-cv-01129
- Edward Davila
- Dec. 7, 2023
Background
Carl Zeiss and Sigray filed statements asking the court to decide whether materials connected to Carl Zeiss’s February 23, 2023 motion for discovery sanctions should be sealed. Carl Zeiss withdrew the sanctions motion on April 18, 2023, but the sealing motions remained pending. The opinion states that Judge Edward Davila had directed the parties to file responsive statements.
Because the sealing requests concerned a discovery-sanctions motion, the court applied the lower “good cause” standard under Federal Rule of Civil Procedure 26(c), rather than the stronger standard generally applied to materials accompanying dispositive motions.
Carl Zeiss’s sealing request
Sigray filed the request associated with Docket No. 134. Carl Zeiss responded through a declaration from Daniel Sims, identified as its “General Manager & Head of X-Ray Microscopy.” Carl Zeiss asserted that the documents contained confidential, proprietary, and competitive technical information constituting trade secrets. It argued that disclosure could give competitors an unfair competitive advantage and harm its ability to compete.
The court found good cause to seal the documents identified by Carl Zeiss because they contained trade secrets. It ordered the following exhibits sealed in their entirety: Docket Nos. 134-2, 134-3, 134-4, 134-5, 134-6, 134-7, 134-8, 134-9, 134-11, and 134-12.
Sigray’s sealing request
Carl Zeiss filed the request associated with Docket No. 143. Sigray did not file a timely response, but its counsel submitted a statement asking that Docket No. 143-1 remain sealed. Sigray asserted that the document contained highly confidential corporate personnel information.
The court found good cause to seal Docket No. 143-1 because it contained information about Sigray employees that could cause annoyance, embarrassment, or oppression if made public. The court ordered Docket No. 143-1 sealed in its entirety. It ordered that Docket Nos. 143-2 and 143-3 not be sealed and that they be filed on the public docket by December 14, 2023.
Disposition
The court granted the administrative sealing motions and terminated Docket Nos. 134 and 143. The order was signed by United States Magistrate Judge Virginia K. Demarchi.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.