Medidata Solutions, Inc. v. Veeva Systems Inc.
- Jed Rakoff
- 1:17-cv-00589
- U.S. District Court · Southern District of New York
- 3
In Medidata v. Veeva, Judge Schofield granted continued sealing of redacted summary-judgment submissions containing confidential business and personal information.
Medidata Solutions, Inc., MDSOL Europe Limited, Veeva Systems Inc., and third parties whose confidential business or private personal information appeared in Medidata’s summary-judgment submissions.
What happened
In Medidata Solutions, Inc. v. Veeva Systems Inc., Veeva asked the court to keep redactions and sealing in Medidata’s summary-judgment submissions. The request covered Veeva’s internal information, third-party private information, and information Medidata claimed was confidential or a trade secret.
The court explained that court records are generally presumed open to the public, but confidentiality interests can justify sealing. It also noted that disputes over whether information was actually Medidata’s confidential or trade-secret information were not suitable for decision on a sealing request.
Judge Lorna G. Schofield granted the request to retain the current redactions and sealing in Medidata’s submissions. The ruling addressed access to court filings, not the parties’ underlying substantive disputes.
The detailed version
- Medidata Solutions, Inc. v. Veeva Systems Inc. · No. 1:17-cv-00589
- Jed Rakoff
- July 6, 2020
Background
Veeva submitted a letter motion asking the court to allow continued sealing of Veeva and third-party confidential information in Medidata’s summary-judgment submissions. The submissions were identified as Dkts. 312–318 and 343–351. Veeva’s request followed Medidata’s separate request concerning Veeva’s submissions.
The requested sealing involved references to internal Veeva information and private personal information belonging to third parties. That information was extensively intermingled with information Medidata claimed was confidential or constituted trade secrets. Veeva argued that the information was the type the court routinely protects from public disclosure and that it was difficult to separate the different parties’ confidentiality interests because of the breadth of Medidata’s claims and the way Medidata presented its arguments.
Legal standard
The court applied the presumption of public access to judicial documents. Under the cited standard, that presumption may be overcome when countervailing factors under the common-law access framework or higher values under the First Amendment framework justify sealing. Relevant considerations include the scope of the sealing request, possible harm from disclosure, the public interest, whether the parties rely on the information to prove their claims, and whether the information is central or merely related to the adjudication.
The court also stated that the parties’ substantive disputes about whether particular information was Medidata’s confidential information or a trade secret were not suitable for resolution through a motion to seal.
Ruling
Judge Lorna G. Schofield granted the request to retain all current redactions and sealing in Medidata’s submissions. The ruling therefore continued the protection of the identified Veeva and third-party information in those filings. The opinion did not decide the underlying summary-judgment issues or determine whether the disputed information was actually Medidata’s confidential information or a trade secret.
Scope of this summary
This was a procedural order about sealing court submissions. The provided materials contain a conflicting judge reference: the supplied case metadata identifies Jed Rakoff, while the opinion text is addressed to and bears an order from Lorna G. Schofield. This summary identifies Judge Schofield because she issued the sealing ruling shown in the opinion text.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.