Dental Monitoring SAS v. Align Technology, Inc.
- William Alsup
- 3:22-cv-07335
- U.S. District Court · Northern District of California
- 3
In Dental Monitoring v. Align, Judge Liam Alsup denied most sealing requests, granting one request for Align’s internal technical exhibit.
Dental Monitoring SAS and Align Technology, Inc., particularly their ability to keep specified discovery and technical documents from public access.
What happened
Dental Monitoring SAS and Align Technology, Inc. filed motions about sealing documents connected to a discovery letter and the parties’ upcoming summary-judgment motions.
The court said materials connected to the case’s merits generally may be sealed only for compelling reasons, and that requests must explain the harm from disclosure and be narrowly tailored. It found Align’s explanations insufficient for most of the requested redactions.
Judge Liam Alsup denied Dental Monitoring’s sealing request for its discovery letter and Align’s interrogatory responses. He granted Align’s request to seal one internal document about its Virtual Care AI Aligner Fit Product Family but otherwise denied Align’s request.
The detailed version
- Dental Monitoring SAS v. Align Technology, Inc. · No. 3:22-cv-07335
- William Alsup
- Feb. 13, 2024
Background
This order addressed administrative motions to seal filed before the parties’ summary-judgment motions in this patent case. Dental Monitoring filed a discovery letter and provisionally submitted under seal an unredacted version of the letter and an excerpt from Align’s supplemental interrogatory responses. Align separately sought to seal portions of two exhibits and all of a third exhibit attached to its response letter.
Legal standard
The court explained that judicial records more than tangentially related to the merits may be sealed only upon a showing of “compelling reasons.” Records only tangentially related to the merits may be sealed for “good cause.” A sealing request must identify the private or public interests supporting sealing, the injury that disclosure would cause, and why a less restrictive option would not suffice. The proposed sealing must also be narrowly limited to material that can properly be kept from public view. General statements, reliance on a protective order, or vague claims of competitive harm are not enough.
Rulings
As to Dental Monitoring’s discovery letter, the court denied the request to seal the letter because Align had already filed an unredacted copy and provided no justification for sealing it. The court also denied the request concerning Align’s interrogatory responses. Align had sought to redact technical information about its products and services, server locations, and personal information about two employees. The court found that the proposed redactions were not sufficiently sensitive or specific to justify sealing.
As to Align’s response letter, the court granted the motion to seal the third exhibit. That exhibit was an internal document describing the architecture of Align’s Virtual Care AI Aligner Fit Product Family, and the court found little current public interest in those details because they were only tangentially important to the letter’s merits. The court otherwise denied Align’s motion, finding its assertion that competitors could gain an unfair advantage from the remaining technical information too vague. Documents that had to be refiled were required to be submitted in compliance with the order by March 12, 2024, at 12:00 p.m.
Disposition
The court denied Dental Monitoring’s sealing requests. It granted Align’s sealing motion as to the third exhibit and otherwise denied Align’s motion. The order was entered by Judge Liam Alsup on February 13, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.