Nespresso USA, Inc. v. Williams-Sonoma, Inc.

Background

Williams-Sonoma, Inc. asked the court for permission to redact and file under seal portions of its January 19, 2021 letter concerning a subpoena for documents issued to Belmoca, identified in the letter as Williams-Sonoma’s Belgian capsule supplier. Williams-Sonoma also asked to file Appendix B under seal in its entirety.

Williams-Sonoma said the materials contained sensitive, nonpublic information about the parties’ 2020 settlement discussions and information designated “Attorneys’ Eyes Only” under the court’s protective order. It specifically identified information concerning the settlement negotiations and a vendor agreement between Belmoca and Williams-Sonoma.

Court’s action

The letter discussed the standard for sealing judicial documents under Lugosch v. Pyramid Co. of Onondaga. That standard requires a court to consider whether the material is a judicial document, determine the strength of the public-access presumption, and weigh that presumption against competing interests such as privacy. Williams-Sonoma argued that the presumption was low because the information involved settlement negotiations and material exchanged in discovery. Discovery is the evidence-gathering phase of a lawsuit.

The order states: “Pursuant to Williams-Sonoma’s letter motion above, the Court respectfully requests that the Clerk of Court seal the document filed at ECF 90 in this case.” The court’s stated action was therefore to direct sealing of the document filed at electronic docket entry 90. The opinion text does not separately state a disposition concerning Appendix B.

Judge and procedural posture

Judge Katharine H. Parker issued the order dated January 20, 2021. This was a procedural order concerning sealing and public access to court filings; it did not decide the parties’ underlying dispute.