Guardant Health, Inc. v. Natera, Inc.
- Edward Chen
- 3:21-cv-04062
- U.S. District Court · Northern District of California
- 2
In Guardant Health v. Natera, Judge Chen ordered narrower, supported sealing requests and warned that noncompliance could lead to denial.
Guardant Health, Inc. and Natera, Inc., whose sealing motions were subject to revision. The moving parties had to narrow their requested redactions and provide supporting declarations by June 5, 2024.
What happened
Guardant Health, Inc. v. Natera, Inc. concerned several requests by the parties to keep documents and portions of documents from public view. The court said the requests were generally too broad.
The court explained that requests to seal must identify the legal standard, the interests supporting secrecy, the harm from disclosure, and why narrower redactions would not be enough. For records connected to motions resolving claims, the requesting party must show specific, compelling reasons, such as confidential business information that could harm competitive standing or trade secrets.
Judge Edward M. Chen ordered the parties to submit revised motions by June 5, 2024. They had to narrow their redaction requests and provide declarations explaining why each redaction met the applicable local rule. The court warned that failing to comply could result in complete denial of the motions.
The detailed version
- Guardant Health, Inc. v. Natera, Inc. · No. 3:21-cv-04062
- Edward Chen
- May 29, 2024
Background
The parties filed several administrative motions asking the court to file documents under seal. The motions were identified as Docket Nos. 369, 441, 451, 454, 463, 464, 466, 506, and 517. The court stated that the parties' proposals were generally too broad.
Legal standard
The court explained that a motion for administrative relief must specifically state the reasons supporting it. Under the district's local rules, a motion to seal must identify the applicable legal standard and explain the legitimate private or public interests supporting sealing, the injury that would result from disclosure, and why a less restrictive alternative would not be sufficient.
For dispositive motions and judicial records attached to them, the party seeking secrecy must show compelling reasons supported by specific factual findings. The court stated that information may be sealed when it is confidential business information that could harm a litigant's competitive standing or when it is a trade secret. Simply referring to a general category of confidentiality or privilege, without explaining how it applies to particular documents, is not enough.
Examples discussed by the court
The court noted that Natera sought to seal eighteen entire exhibits connected to its motions in limine but gave no reason for sealing them. The exhibits included expert depositions and internal emails that, on their face, did not appear to contain confidential business information or trade secrets. The court also noted that Natera sought to redact a statement accusing Guardant of manipulating and misrepresenting the results of a study. The court said that placing Guardant in an unfavorable light did not satisfy the compelling-reasons standard.
Order
For all nine identified docket entries, the moving party was required to resubmit compliant administrative motions to seal by Wednesday, June 5, 2024. The parties were required to narrow their requests for redactions and provide declarations establishing why each redaction fell within the meaning of the local rule. The court warned that failure to comply could result in complete denial of the motion. The opinion does not state that the court finally granted or denied any of the identified sealing motions at that time.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.