Spectrum Dynamics Medical Limited v. General Electric Company

Background

Spectrum Dynamics Medical Limited and General Electric Company jointly requested redactions to Document 200, the transcript of the parties’ appearance before Magistrate Judge Katharine H. Parker on February 25, 2021. The request was made under Federal Rule of Civil Procedure 5.2(e), the judge’s individual practice rules, and the parties’ stipulated confidentiality and protective order.

The requested redactions covered pages 6–8, 10, 16–17, 21, 25–34, and 37. The parties stated that the transcript discussed GE’s development of a product that was not publicly available and confidential details of Spectrum’s alleged trade secrets. They characterized the information as competitively sensitive and proprietary, and as “Highly Confidential — Attorneys’ Eyes Only” information under the protective order.

Parties’ Arguments

The parties relied on the presumption of public access to judicial documents and the exception for information whose disclosure could harm a litigant’s competitive position. They argued that disclosure would pose a substantial risk of harm to GE or Spectrum, that the information was not relevant to the court’s resolution of any issue, and that the request was narrowly tailored. They also argued that the redactions would not deprive the public of access to critical information.

Ruling

The court granted the application. The ruling permitted the requested redactions in the publicly available version of the February 25, 2021 transcript. The document concerns access to court records and did not decide the underlying dispute between Spectrum Dynamics Medical Limited and General Electric Company.