Willis Electric Co., Ltd. v. Polygroup Limited
- Joan Ericksen
- 0:15-cv-03443
- U.S. District Court · District of Minnesota
- 2
Willis Electric v. Polygroup Macau: Judge Menendez kept documents sealed because the related motions did not involve judicial records.
The parties and other persons seeking access to the documents filed in connection with the defendants’ motions; the Clerk was directed to keep specified docket entries under seal.
What happened
In Willis Electric Co., Ltd. v. Polygroup Macau Limited (BVI), et al., the parties jointly asked the District of Minnesota to keep documents temporarily sealed. The documents related to motions about compelling discovery, changing a prior-art statement, and adding an inequitable-conduct counterclaim.
The court agreed that the documents should remain sealed. It said the documents were not judicial records because the motions did not require the court to exercise its constitutional judicial power. The court directed the clerk to keep the listed docket entries under seal, while noting that some documents filed conventionally would not require a separate clerk instruction.
Judge Katherine Menendez entered the order on March 2, 2021.
The detailed version
- Willis Electric Co., Ltd. v. Polygroup Limited · No. 0:15-cv-03443
- Joan Ericksen
- Mar. 2, 2021
Background
The parties filed a joint motion under Local Rule 5.6 concerning documents that had been filed temporarily under seal. The documents were submitted in connection with defendants’ motion to compel, motion to amend their prior-art statement, and motion to amend their answer and add a counterclaim alleging inequitable conduct.
The parties agreed that the listed memoranda, declarations, exhibits, and other filings should remain sealed. The order identifies the documents by docket entry, including entries 553, 555, 557 and its listed attachments, 563, 565, 568, 570, 572 and its listed attachments, and 578. The footnote explains that several other materials were conventionally filed under seal because of an information-security concern.
Court’s Analysis
The court reviewed the documents and concluded that they should remain sealed. It determined that none were “judicial records” because the motions involved were nondispositive and did not call on the court to exercise its Article III powers. A judicial record is a court filing to which the public’s common-law right of access may apply; the court concluded that these materials did not fall within that category in this context.
Disposition
The court directed the Clerk to keep the specified docket entries under seal. For the materials filed conventionally, the court stated that it would not direct the Clerk to keep those entries sealed because they were conventionally filed, but it nevertheless found that the materials could remain sealed in the context of the nondispositive motions. Judge Katherine Menendez signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.