Spectrum Dynamics Medical Limited v. General Electric Company
- Vernon Broderick
- 1:18-cv-11386
- U.S. District Court · Southern District of New York
- 42
In Spectrum Dynamics Medical v. General Electric, Judge Parker granted GE’s request to redact proprietary product-development information from a transcript.
General Electric Company and the other identified defendants and non-party whose counsel requested protection of the information; the public will not see the specified portion of the transcript.
What happened
In Spectrum Dynamics Medical Limited v. General Electric Company, General Electric asked the court to redact one paragraph from a transcript of a December 18, 2020 court appearance. The requested redaction covered a statement by GE’s lawyer about developing a product that was not publicly available.
GE argued that the information was proprietary, competitively sensitive, and covered by the parties’ confidentiality order. It said disclosure could substantially harm GE’s competitive position. Spectrum Dynamics did not object to the request.
Judge Katharine H. Parker granted the request and ordered the requested material redacted from the publicly available transcript. The ruling concerns access to court records, not the parties’ underlying patent dispute.
The detailed version
- Spectrum Dynamics Medical Limited v. General Electric Company · No. 1:18-cv-11386
- Vernon Broderick
- Jan. 1, 2021
Background
General Electric Company (GE) asked the court under Federal Rule of Civil Procedure 5.2(e), the court’s individual practice rules, and the parties’ stipulated confidentiality and protective order to redact part of Document 161, a transcript of the parties’ December 18, 2020 appearance. The request concerned GE’s counsel’s statement at page 18, lines 14 through 18. Spectrum Dynamics did not object.
The requested redaction concerned GE’s development of a product that was not publicly available. GE asserted that the information was proprietary and competitively sensitive, that it qualified as “Highly Confidential — Attorneys’ Eyes Only” information under the protective order, and that disclosure would create a substantial risk of harm to GE. GE also argued that the information was not relevant to the court’s resolution of any issue and that the request was narrowly tailored.
Legal Standard
The court recognized the general presumption that judicial documents should be accessible to the public. It explained that confidentiality may be allowed when countervailing interests outweigh that presumption, including the need to protect an entity from competitive injury and to preserve proprietary business information.
Ruling
Judge Parker granted GE’s request to redact the identified portion of the transcript before the transcript was made publicly available. The ruling protects the identified product-development information while leaving the remainder of the transcript available to the public. The order does not decide the parties’ underlying patent claims or disclose the substance of the redacted statement.
Effect
The redaction applies to the specified portion of Document 161. The opinion text identifies GE and other defendants and a non-party as represented by the requesting attorneys, but it does not explain any further practical effect on those parties.
Read the full 42-page opinion on CourtListener, the free public archive maintained by the Free Law Project.