Medidata Solutions, Inc. v. Veeva Systems Inc.

Background

Medidata Solutions, Inc. and MDSOL Europe Limited asked the court to continue redacting and sealing confidential information contained in Veeva Systems Inc.’s submissions concerning the parties’ cross-motions for summary judgment. The submissions included briefing, declarations, exhibits, and motions.

Medidata argued that the materials contained descriptions, excerpts, and examples of its trade secrets and other confidential business information, including information about its research and development, investments, and business generated through use of the trade secrets. Medidata acknowledged the public’s general interest in court proceedings but argued that disclosure would cause definite and serious injury.

Medidata requested an exception for Exhibit 5 to a declaration filed at docket entries 331, 334, and 341, stating that Veeva had designated the material confidential but Medidata had no confidentiality interest in it.

Legal standard and reasoning

The court applied the common-law presumption of public access to judicial documents. It considered the narrowness of the requested sealing, the potential damage from disclosure, the public interest, the extent to which the parties relied on the material, and whether the material was central or merely secondary to the adjudication.

The opinion states that Medidata’s proposed redactions were narrowly tailored to passages specifically referring to protected information. It also states that the materials involved proprietary business information related to the trade secrets at issue and that similar materials had previously been sealed. Because the material was subsidiary to a pretrial motion rather than directly affecting an adjudication, the court found the public interest in access somewhat diminished.

Ruling

The court granted the request to retain all current redactions and sealing in Veeva’s submissions, except for the declaration exhibit identified at docket entries 331, 334, and 341. The parties were directed to ensure that a copy of that declaration was made publicly available or docketed.

The supplied case metadata identifies Judge Jed Rakoff, but the opinion text is addressed to and appears to be ruled on by Judge Lorna G. Schofield; this summary follows the judge named in the opinion text.