Raptor Trading Systems, Inc. v. Beth
- Ronnie Abrams
- 1:16-cv-03430
- U.S. District Court · Southern District of New York
- 3
In Raptor Trading Systems v. Beth, Judge Abrams granted requests to redact sale-related information from summary-judgment exhibits and ordered unredacted versions sealed.
The parties in the two related actions, Raptor Trading Systems, Inc., and the identified third parties whose names, counsel information, and proposed-sale financial terms were protected from public access.
What happened
Raptor Trading Systems, Inc. v. Beth and the related Wallach v. Lardos actions involved requests to redact information from exhibits filed with the parties’ cross-motions for summary judgment. The requested redactions concerned a potential purchaser of Raptor Trading Systems, Inc., the purchaser’s counsel, and financial terms of the proposed sale.
The court treated the exhibits as judicial documents because they were submitted with summary-judgment motions. That ordinarily creates a strong presumption that the public can access them, but the court found that Raptor’s interest in keeping the proposed sale confidential outweighed that presumption.
Judge Ronnie Abrams granted the requests to redact the identified information and ordered the unredacted exhibits filed under seal. The clerk was directed to terminate the four sealing motions in the two related cases.
The detailed version
- Raptor Trading Systems, Inc. v. Beth · No. 1:16-cv-03430
- Ronnie Abrams
- Sept. 22, 2020
Background
The order addresses sealing motions in two related actions. The parties had filed cross-motions for summary judgment and supporting declarations containing numerous exhibits. The Raptor Parties asked to redact the name of a potential third-party purchaser of Raptor Trading Systems, Inc. and the purchaser’s counsel from two exhibits. Wallach and Beth asked to redact a third party’s name, the third party’s counsel, and certain financial information from several exhibits. The parties provided complete, unredacted versions to each other and the court under separate cover.
Legal standard
The court applied the access test from Lugosch v. Pyramid Co. of Onondaga. First, the court determined whether the materials were “judicial documents”—documents relevant to the court’s work and useful in the judicial process. Because the exhibits were submitted with cross-motions for summary judgment, the court considered them judicial documents. A strong common-law presumption of public access therefore applied.
The court then weighed that presumption against competing considerations. It found that Raptor’s business interest in keeping confidential the identity of a potential purchaser and the specific financial terms of the proposed sale was sufficient to overcome the presumption of access.
Disposition
The court granted the parties’ request to redact the proposed portions of the exhibits filed with their cross-motions for summary judgment. It ordered the unredacted versions filed under seal. The clerk was directed to terminate the motions at Docket Nos. 112 and 115 in Case No. 16-CV-3430 and Docket Nos. 97 and 100 in Case No. 16-CV-5392. Judge Ronnie Abrams did not decide the underlying cross-motions for summary judgment in this order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.