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S.D.N.Y.Procedural orderFiled June 8, 2021

Kumaran v. ADM Investor Services, Inc.

Judge
Gregory Woods
Docket
1:20-cv-03873
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureArbitration
In one sentence

In Kumaran v. ADM Investor Services, Judge Aaron granted plaintiffs’ motion to seal exhibits containing sensitive financial and trading information.

Who this affects

The plaintiffs, whose exhibits were sealed, and members of the public who otherwise could have sought access to those exhibits.

What happened

In Kumaran v. ADM Investor Services, Inc., the plaintiffs asked the court to seal exhibits attached to arbitration pleadings, saying they contained confidential financial and trading data and trade-secret information.

The court recognized that documents filed with a motion to compel arbitration generally carry a presumption of public access. It found that the exhibits contained nonpublic information that could potentially harm the parties competitively if shared with competitors.

Judge Aaron ruled that the interest in keeping the documents confidential outweighed the public-access presumption and granted the plaintiffs’ motion to seal.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Kumaran v. ADM Investor Services, Inc. · No. 1:20-cv-03873
Judge
Gregory Woods
Date
June 8, 2021

Background

Samantha Siva Kumaran and Nefertiti Risk Capital Management, LLC, asked the court to seal certain exhibits attached to arbitration pleadings. They stated that the exhibits contained confidential financial and trading data and trade-secret information.

Court’s analysis

The court applied the test from Lugosch v. Pyramid Co. of Onondaga. It explained that documents filed with a motion to compel arbitration generally are judicial documents, meaning they are subject to a presumption of public access under both common law and the First Amendment.

The court nevertheless found that the exhibits contained nonpublic financial and trading data, along with related communications. It determined that the information was sensitive and potentially damaging if shared with competitors. The court therefore concluded that the interest in maintaining confidentiality outweighed the presumption of public access.

Disposition

Judge Stewart D. Aaron granted the plaintiffs’ motion to seal.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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