Mayo Foundation for Medical Education and Research v. Knowledge to Practice

Background

The court considered the parties’ Corrected Joint Motion Regarding Continued Sealing under District of Minnesota Local Rule 5.6. The parties disagreed about whether documents filed in connection with Mayo’s motion to compel and Knowledge to Practice’s motion to compel production of documents in response to a subpoena should remain sealed.

The opinion describes the underlying case as a dispute over ownership of contractually defined intellectual-property interests in medical board review courses. Knowledge to Practice argued that the temporarily sealed documents contained confidential, proprietary, nonpublic information that was competitively sensitive and central to its business. It argued that disclosure could give competitors an advantage and damage its business. Mayo argued that Knowledge to Practice had not shown a compelling reason or good cause for continued sealing.

Legal standard

The court recognized a common-law right of public access to judicial records. That right is not absolute, however. The court must balance the public’s interest in access against the interests served by keeping information confidential. Local Rule 5.6 similarly provides that information filed with the court should not remain sealed unless the need for confidentiality outweighs the public’s qualified right of access.

Ruling

The court found that Knowledge to Practice overcame the presumption of public access by showing that the documents contained nonpublic, competitively sensitive information central to its business. After reviewing the documents, the court determined that the information concerned Knowledge to Practice’s intellectual-property rights and that its need for confidentiality outweighed the public’s right of access.

The court granted the parties’ Joint Motion for Continued Sealing. It directed the clerk to keep ECF Nos. 55, 63, 63-1, 63-2, 63-3, 63-4, 63-5, 63-6, 63-7, 72, and 75 sealed. Judge Tony N. Leung signed the order.