Sleep Number Corporation v. Young
- Nancy Brasel
- 0:20-cv-01507
- U.S. District Court · District of Minnesota
- 3
In Sleep Number v. Young, Judge Wright granted the parties’ motion to keep specified court filings sealed.
The order affects Sleep Number Corporation, Steven Jay Young, Carl Hewitt, UDP Labs, Inc., and the public’s access to the specified court filings.
What happened
Sleep Number Corporation, Steven Jay Young, Carl Hewitt, and UDP Labs, Inc. jointly asked the District of Minnesota to continue sealing documents filed with Sleep Number’s request concerning a temporary restraining order or preliminary injunction.
The parties agreed, or did not object, to keeping several filings sealed because they contained commercially sensitive business and alleged trade-secret information. They disagreed about one publicly filed document containing email discussions of possible settlement scenarios.
The court ruled that the joint motion was granted and ordered the listed documents, including the settlement-related filing, to remain under seal. Judge Elizabeth Cowan Wright said the order did not decide whether any information was legally a trade secret.
The detailed version
- Sleep Number Corporation v. Young · No. 0:20-cv-01507
- Nancy Brasel
- Aug. 2, 2022
Background
The parties filed a Joint Motion Regarding Continued Sealing under District of Minnesota Local Rule 5.6(d). The motion concerned documents filed under seal in connection with Sleep Number Corporation’s motion for a temporary restraining order or, alternatively, to modify a preliminary injunction order.
Documents the parties did not dispute
The parties agreed, or did not object, to continued sealing of Docket Entries 386, 389-1, 390, 390-1, 390-2, 390-3, 390-4, 390-5, 399, 401, 404, 404-1, 404-2, 404-3, and 404-4. They represented that these documents contained confidential and trade-secret information that was commercially and competitively sensitive. After reviewing the documents, the court concluded that the need to keep them sealed outweighed the public’s right of access.
The court expressly stated that its sealing orders did not determine whether information identified by a party as a trade secret actually was, or was not, a trade secret.
Docket Entry 388-1
The parties disagreed about Docket Entry 388-1, which Sleep Number had filed publicly. The defendants sought to seal it because part of an email chain contained settlement discussions they said were protected by Rule 408 of the Federal Rules of Evidence. Sleep Number responded that the document had not been designated confidential and that it disclosed no specific settlement terms, only a general desire to settle.
The court explained that Rule 408 concerns whether evidence may be admitted, not whether a court filing must be kept confidential. The court nevertheless found that the document listed possible general settlement scenarios and that, at this stage of the case, encouraging frank settlement communications outweighed the public’s interest in accessing the information.
Ruling
Judge Elizabeth Cowan Wright granted the parties’ Joint Motion Regarding Continued Sealing. The court ordered the specified docket entries to remain sealed and directed the Clerk’s Office to place Docket Entry 388-1 under seal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.