DoseLogix, LLC v. Reflex Medical Corp.

Background

DoseLogix, LLC and Reflex Medical Corp. filed a joint motion asking the court to continue sealing documents filed in connection with several motions. Those motions included DoseLogix’s motion for summary judgment on specified patent claims, motions concerning expert testimony, and Reflex Medical’s motion for summary judgment and exclusion of testimony.

The court explained that the underlying motions had been denied without prejudice by District Judge Eric C. Tostrud after the parties jointly moved to stay the case pending the outcome of reexamination proceedings. As a result, the documents at issue had not played a role in the court’s exercise of its constitutional decision-making authority.

Analysis

The court recognized a common-law right of public access to judicial records, but explained that the right is not absolute. It weighed the public’s interest in accessing the filings against the parties’ confidentiality interests. Filings connected to summary-judgment motions receive a stronger presumption of public access, but the court found that the documents had little value for monitoring the federal courts because the related motions had been denied without prejudice. The filings appeared to contain sensitive business information, and public versions with narrowly tailored redactions had been filed when practicable.

Order

Judge Dulce J. Foster concluded that the parties’ confidentiality interests outweighed the public’s minimal interest in accessing the documents. The court granted the Joint Motion for Continued Sealing in full and directed the Clerk to keep ECF Nos. 84, 86, 88, 96, 99, 99-1 through 99-10, 109, 112, 115, 122, 125, and 125-1 under seal. This order addressed access to the filings; it did not decide the underlying patent or expert-testimony motions.