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

Background

Williams-Sonoma asked permission to redact and file under seal portions of its January 28, 2021 letter responding to a letter from Nespresso USA. Williams-Sonoma said the letter contained highly sensitive, nonpublic information about the parties’ confidential settlement negotiations.

Williams-Sonoma stated that it was seeking to seal only specific information related to those negotiations. It also publicly filed a version of the letter with proposed redactions and submitted an unredacted version under seal.

Legal standard presented

The letter discussed the Second Circuit’s framework for sealing court records. That framework asks whether the material is a judicial document, determines the strength of the public’s right to access it, and weighs that right against competing interests. Williams-Sonoma did not dispute that the letter was a judicial document, but argued that the settlement-related information received limited public-access protection because it concerned material covered by Rule 408 of the Federal Rules of Evidence.

The opinion text primarily consists of Williams-Sonoma’s sealing request and does not provide a separate explanation of the court’s reasoning beyond the ruling shown in the filing.

Ruling

Judge Katharine H. Parker marked the application “GRANTED.” The court also requested that the Clerk of Court place ECF No. 101 under seal, limiting access to the parties and the court. The ruling concerned sealing and redaction of a filing; it did not decide the parties’ underlying dispute.