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

Background

Nespresso asked the court for permission to redact and file under seal selected portions of its January 27, 2021 letter. The letter contained information related to confidential settlement negotiations. The filing stated that Nespresso had discussed and agreed on the proposed redactions with Williams-Sonoma.

Nespresso’s request concerned docket entries 98 and 111. The filing said the proposed redactions were limited to information related to settlement negotiations and were similar to information sealed in earlier filings in the case.

Legal basis presented

The filing described the Second Circuit’s three-step approach to sealing judicial documents: determine whether the material is a judicial document, assess the weight of the public-access presumption, and then weigh interests favoring confidentiality against that presumption. Nespresso argued that the material was protected under Federal Rule of Evidence 408 and that some of it was confidential under the Southern District of New York’s mediation-program procedures. It also argued that the redactions were narrowly tailored and that the parties had significant privacy interests in protecting settlement discussions.

Ruling

Judge Katharine H. Parker granted the application. The docket text states that the documents filed at docket numbers 98 and 111 were to be placed under permanent seal, with access limited to the parties and the court. The provided text does not include a separate written explanation by the court beyond the grant of the application and the sealing instruction.