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N.D. Cal.Procedural orderFiled Feb. 1, 2024

Ripple Services, Inc. v. Betur Inc.

Judge
Jacquelyn Corley
Docket
3:23-cv-06215
Court
U.S. District Court · Northern District of California
Pages
4
Civil ProcedureContract
In one sentence

In Ripple Services v. Betur, Judge Cisneros denied Ripple’s motion to seal complaint portions without prejudice for lack of compelling reasons.

Who this affects

Ripple Services, Inc. must either renew its request to seal portions of the complaint within 14 days while addressing the court’s concerns or file a public version of the complaint. Betur Inc. had not appeared, and the ruling also preserves public access to the complaint.

What happened

Ripple Services, Inc. v. Betur Inc. concerns Ripple’s lawsuit alleging that Betur breached a written settlement agreement. Ripple asked to keep information about the agreement’s installment schedule and payment amounts out of the public complaint.

Ripple argued that the settlement agreement was confidential and that disclosure could harm its competitive position and future negotiations. The court applied the requirement that sealing a complaint must be supported by compelling reasons, and found that Ripple had not shown that the information was a trade secret or related to how Ripple operates its business.

Judge Lisa Cisneros denied Ripple’s motion to seal without prejudice. The court allowed Ripple 14 days to renew the request while addressing the identified problems; otherwise, Ripple must file a public version of the complaint.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Ripple Services, Inc. v. Betur Inc. · No. 3:23-cv-06215
Judge
Jacquelyn Corley
Date
Feb. 1, 2024

Background

Ripple Services, Inc. sued Betur Inc., doing business as Coins.ph, for breach of contract related to a written settlement agreement entered in May 2023. The settlement followed a dispute about fees that Betur was charging under a 2018 Exchange Integration Agreement. Betur had not appeared in the case when the court considered Ripple’s motion.

Motion to Seal

Ripple asked to file portions of its complaint under seal under Local Rule 79-5. The information included the settlement agreement’s installment-payment schedule and payment amounts. Ripple argued that the agreement was confidential and that public disclosure could harm its competitive standing and ability to negotiate future agreements.

Because the complaint was more than tangentially related to the merits of the case, the court applied the “compelling reasons” standard. Under that standard, a party must show a strong justification for restricting public access to court records. The court noted that Ripple did not say whether the settlement agreement contained a confidentiality provision and did not provide the agreement for the court to review. The court also explained that a private confidentiality agreement alone does not establish compelling reasons to seal information.

The court distinguished cases involving trade secrets or competitively sensitive information about business operations, such as pricing or contract terms governing how a company does business. It found that the information Ripple sought to seal concerned how Ripple resolved a contract dispute, rather than how Ripple operated its business. Although a competitor might use the information to its advantage, the court found that this concern did not establish compelling reasons for sealing.

Disposition

Judge Lisa Cisneros denied Ripple’s motion to seal without prejudice. Ripple may renew the motion within 14 days of the order by addressing the deficiencies identified by the court. If Ripple does not renew the motion, it must file a public version of the complaint by the applicable deadline.

The authoritative version

Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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