Sunlight Financial LLC v. Hinkle
- Jesse Furman
- 1:21-cv-06680
- U.S. District Court · Southern District of New York
- 2
Sunlight Financial v. Hinkle: Judge Nathan granted plaintiffs’ motion to seal exhibits and redact confidential business information.
The plaintiffs, whose two exhibits may be filed in unredacted form under seal while confidential material is redacted from the public versions.
What happened
In Sunlight Financial LLC et al. v. Hinkle et al., the plaintiffs asked to seal unredacted versions of two exhibits supporting their requests for a temporary restraining order and preliminary injunction, while redacting confidential material from the public versions.
The court granted the unopposed motion. It found that the proposed redactions were narrowly tailored to protect competitive business information, including customer lists that qualified as trade secrets under New York law. The court concluded that protecting this information outweighed the public’s presumed right of access.
Judge Alison J. Nathan issued the order on January 10, 2022.
The detailed version
- Sunlight Financial LLC v. Hinkle · No. 1:21-cv-06680
- Jesse Furman
- Jan. 10, 2022
Background
The plaintiffs moved to file under seal the unredacted versions of two exhibits attached to the declaration supporting their motions for a temporary restraining order and preliminary injunction. They also asked to redact confidential material from the publicly filed versions. The motion was unopposed.
Legal standard
The court applied the three-part test from the Second Circuit’s decision in Lugosch v. Pyramid Co. of Onondaga. The test requires the court to determine whether the materials are judicial documents, assess the strength of the common-law presumption of public access, and balance competing interests against that presumption. The court noted that a confidentiality order alone does not automatically justify withholding documents from public view.
Ruling
The court granted the plaintiffs’ motion. After reviewing the proposed redactions, it found that they were narrowly tailored to protect competitive business information. The exhibits contained the plaintiffs’ customer lists, which the court found qualified as trade secrets under New York law because they had been developed through substantial effort, kept confidential, and were not otherwise readily ascertainable. The court concluded that the sensitivity of this information outweighed the presumption of public access.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.