Sleep Number Corporation v. Young
- Nancy Brasel
- 0:20-cv-01507
- U.S. District Court · District of Minnesota
- 2
In Sleep Number v. Young, Judge Wright granted continued sealing for four docket entries containing confidential business information despite the public’s access interest.
Sleep Number Corporation, Steven Jay Young, Carl Hewitt, UDP Labs, Inc., and members of the public seeking access to the sealed filings.
What happened
In Sleep Number Corporation v. Young, the parties jointly asked the U.S. District Court for the District of Minnesota to continue sealing four docket entries. The parties agreed that three entries contained commercially sensitive trade-secret and business information; they disagreed about one email.
The court found that the three agreed entries contained information whose confidentiality outweighed the public’s right to access them. For the disputed email, the court found that it discussed UDP Labs’s business plans and that the public’s need to know the information did not outweigh the defendants’ interest in confidentiality at this stage.
Judge Elizabeth Cowan Wright granted the joint motion. Docket Entries 166, 167, 167-1, and 176 will remain sealed, although the court said the decision may be reconsidered if the information is later filed with and considered during a dispositive motion.
The detailed version
- Sleep Number Corporation v. Young · No. 0:20-cv-01507
- Nancy Brasel
- May 28, 2021
Background
The court considered the parties’ Joint Motion Regarding Continued Sealing under District of Minnesota Local Rule 5.6(d). The motion concerned Docket Entries 166, 167, 167-1, and 176, which had been filed under seal.
The parties agreed that Docket Entries 167, 167-1, and 176 should remain sealed because they contained trade-secret information and commercially and competitively sensitive business information. The court reviewed those documents and concluded that the need to protect the information outweighed the public’s right of access, particularly given the case’s procedural posture. The court noted that redacted versions of Docket Entries 167 and 176 had been publicly filed.
The parties disagreed about Docket Entry 166. Sleep Number argued that the document did not qualify as confidential under Federal Rule of Civil Procedure 26(c). The defendants argued that the email contained confidential conversations between business associates and discussed UDP Labs’s confidential business plans. The court found that, although the email was general about possible future product options, it still contained information about UDP Labs’s business plans. At this stage, the court concluded that the public’s need to know those plans did not outweigh the defendants’ interest in keeping them confidential.
Ruling
Judge Elizabeth Cowan Wright granted the Joint Motion Regarding Continued Sealing. Docket Entries 166, 167, 167-1, and 176 will remain sealed.
The court emphasized that its decision was not determinative of whether the information would remain sealed in the future if it were filed and considered in connection with a future dispositive motion. A dispositive motion is a motion that could resolve some or all of the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.