JLM Couture, Inc. v. Gutman

Background

JLM Couture, Inc. asked the court to permit redactions in three documents from its employment relationship with Hayley Paige Gutman: an initial employment agreement dated July 13, 2011; an amendment dated July 15, 2014; and a February 2, 2019 notice concerning additional compensation. The documents were filed as Exhibits 2, 62, and 66 to the declaration supporting JLM’s request for a temporary restraining order.

The court had previously determined that provisions concerning trademark rights, intellectual property, and advertising duties were judicial documents relevant to the litigation. It found that an earlier sealing order was overbroad as to the exhibits comprising the employment agreement, while the ruling did not address Exhibits 55 and 64. The court directed JLM to justify any requested redactions.

Requested Redactions

JLM sought to redact Gutman’s salary and other compensation information from the employment agreement and its amendment, as well as the additional compensation amount in the 2019 notice. JLM argued that disclosure could give competitors an advantage, harm its relationships with other employees, and weaken its negotiations with current and prospective designers. JLM cited the rule that sealing or redaction may protect interests such as competitive injury. Gutman’s attorney consented to the proposed redactions.

Ruling

The court granted JLM’s request. It directed JLM to file Exhibits 2, 62, and 66 on the electronic filing system in the redacted forms illustrated in sealed docket entries 10-1, 10-2, and 10-3. Those entries were to remain restricted to access by the plaintiff and defendant. This was an ancillary filing-access ruling, not a decision on the underlying claims in the case.