Domaine Carneros, Ltd v. Lea Trading LLC

Background

Lea Trading LLC filed a motion to dismiss or, alternatively, transfer the case. The motion argued, among other things, that the court lacked personal jurisdiction and that venue was improper. Domaine Carneros opposed that motion and submitted exhibits with information redacted. After the court directed Domaine Carneros either to file unredacted exhibits publicly or seek permission to seal them, Domaine Carneros moved to seal Exhibit A to a supporting declaration.

The requested redactions covered a nonparty declarant’s personal email address, personal shipping address, and personal billing address. Lea Trading opposed the sealing request and stated that its counsel had asked Domaine Carneros’s counsel to provide the information, but the request was refused.

Sealing Decision

The court explained that judicial records generally carry a strong presumption of public access. For records connected more than indirectly to the merits, a party ordinarily must show compelling reasons that outweigh public access. The court found that compelling reasons supported redacting the personal contact information and that the requested redactions were narrowly tailored. It therefore granted Domaine Carneros’s administrative motion to seal.

Disclosure to Lea Trading

The court treated public disclosure and disclosure to Lea Trading as separate issues. Because Domaine Carneros had attached the declaration and exhibit as evidence supporting its opposition to Lea Trading’s motion, the court stated that it was unclear what authority supported withholding the redacted information from Lea Trading itself.

The court ordered Domaine Carneros to show cause in writing by June 18, 2024, why it should not be required to provide Lea Trading with an unredacted copy of Exhibit A. The order did not decide Lea Trading’s motion to dismiss or alternative request to transfer venue.