Splunk Inc. v. Cribl, Inc.
- William Alsup
- 3:22-cv-07611
- U.S. District Court · Northern District of California
- 4
In Splunk v. Cribl, Judge Alsup denied four sealing motions because vague competitive-harm claims did not overcome the public’s interest in access.
Splunk Inc., Cribl, Inc., Clint Sharp, and the public’s access to the court filings.
What happened
Splunk Inc. v. Cribl, Inc. and Clint Sharp concerned requests to keep parts of filings and exhibits secret in connection with Rule 12 motions and discovery disputes. The requests involved materials that defendants said contained Cribl’s confidential business information.
The court found that defendants relied on general statements about possible competitive harm rather than identifying specific harm from particular passages. It also noted that some information was already public and that other material involved statements related to the claims and defenses.
Judge William Alsup denied all four sealing motions. He ordered the documents refiled in compliance with the order by March 29, 2024, at noon. The order did not decide the underlying Rule 12 or discovery disputes.
The detailed version
- Splunk Inc. v. Cribl, Inc. · No. 3:22-cv-07611
- William Alsup
- Feb. 13, 2024
Background
This order addressed four administrative motions to seal filed alongside Rule 12 motion papers and discovery letter briefs. A motion to seal asks the court to restrict public access to filings or portions of filings. Splunk and the defendants sought sealing based on claimed confidentiality involving Cribl’s internal strategies, system designs, business practices, and services.
The court explained that court records connected more than tangentially to the merits may be sealed only for “compelling reasons.” Records only tangentially related to the merits may be sealed upon a lesser showing of “good cause.” Under the Northern District of California’s local rule, a sealing request must identify the private or public interests supporting secrecy, explain the injury that would result from disclosure, explain why a less restrictive alternative would not suffice, and narrowly identify the material that should remain sealed. Supporting declarations must provide specific explanations rather than boilerplate assertions or reliance only on a protective order or confidentiality designation.
Rulings on the Four Motions
1. Splunk’s opposition to defendants’ motion for partial judgment on the pleadings. Defendants claimed that the material revealed Cribl’s internal strategies and business practices and could affect its competitive standing. The court found that this explanation was vague and not tied to specific passages. The court also stated that the request appeared aimed at hiding unflattering statements related to the claims and defenses, rather than preventing competitive harm. The motion to seal was DENIED.
2. Defendants’ reply supporting their motion for partial judgment on the pleadings. Defendants sought to seal passages summarizing documents the judge had ordered unsealed. The court again found the competitive-harm assertions vague and mismatched to the redacted material, which included statements related to the litigation. The motion to seal was DENIED.
3. Splunk’s discovery letter brief. Defendants again relied on general statements about possible competitive harm. The court found that the material went to the heart of the discovery dispute, had been discussed in open court, and had not been shown to create harm outweighing the public interest. The motion to seal was DENIED. The court separately noted that Splunk’s request to produce a document that defendants had allegedly redacted based on privilege had previously been denied without prejudice, allowing Splunk to move again on a better record.
4. Defendants’ response to Splunk’s discovery letter brief. Defendants sought to seal parts of the response and exhibits based on similar assertions about internal business information. The court found that the details were either already public or had not been shown to cause competitive harm. The motion to seal was DENIED.
Result
The court ordered all documents to be refiled in full compliance with the order by March 29, 2024, at 12:00 p.m. This order ruled on access to the filings; it did not resolve the underlying Rule 12 motions or the discovery disputes.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.