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

Background

Williams-Sonoma, Inc. filed a letter motion asking to redact and partly seal the transcript of a March 4, 2021 telephone conference. Williams-Sonoma sought to keep the full transcript under seal while making a redacted version publicly available. It identified information concerning the parties’ confidential settlement negotiations in 2020 and possible future settlement negotiations.

Williams-Sonoma stated that the proposed redactions were limited to specific settlement-related information. It relied on the Second Circuit’s framework for sealing judicial documents, which requires the court to consider whether the material is a judicial document, the strength of the public-access presumption, and competing interests such as privacy.

Court’s Analysis

The opinion states that Williams-Sonoma did not dispute that the hearing transcript was a judicial document. The court considered the public-access presumption low because the proposed redactions concerned information protected under Rule 408 of the Federal Rules of Evidence and confidential settlement communications. The court also recognized Williams-Sonoma’s privacy interests in the settlement information.

Ruling

The court agreed that the transcript at ECF No. 144 should be redacted, but only to the extent proposed by Williams-Sonoma. The court ordered Williams-Sonoma to submit the Southern District’s Redaction Request Form to the court reporter by March 29, 2021. The opinion does not state that the entire transcript was sealed without redactions or that any underlying claim was resolved.