Keystone Foods Holdings Limited v. Tyson Foods, Inc.

Background

The plaintiff asked for permission to file under seal an excerpt from the Disclosure Schedule to the Share Purchase Agreement negotiated with Tyson Foods, Inc. The excerpt concerned the parties’ dispute over Tyson’s purchase of Beef Holdings. The opinion identifies the plaintiff in the caption as Keystone Foods Holdings Limited but refers to it in the body as Beef Holdings.

The requested excerpt was related to Tyson’s motion to compel arbitration and dismiss several counts of the complaint. Beef Holdings said it did not have an interest in keeping the excerpt confidential, but noted that Tyson might object because the excerpt contained confidential business information concerning Beef Holdings/Keystone. Tyson did not respond to the sealing request.

Legal standard

The court explained that judicial documents are generally subject to a common-law right of public access. A party seeking to seal a judicial document bears the burden of overcoming that presumption. The court must weigh the document’s role in the judicial process and the value of public access against competing interests, including privacy and confidentiality concerns.

Ruling

The court found that Beef Holdings did not meet its burden because it provided little to no information explaining why the excerpt’s contents required confidentiality. Judge Andrew L. Carter, Jr. therefore denied the motion to file the document under seal and directed Beef Holdings to file it on the public docket by October 2, 2020. The order states that this resolved docket entry 57.