CT Espresso LLC v. Lavazza Premium Coffees Corp.
- Denise Cote
- 1:22-cv-00377
- U.S. District Court · Southern District of New York
- 2
In CT Espresso v. Lavazza, Judge Broderick denied without prejudice a request to seal complaint materials because confidentiality alone did not justify sealing.
CT Espresso LLC's request to keep the unredacted complaint and Exhibit A from public access was denied without prejudice. Lavazza Premium Coffees Corp. and Luigi Lavazza S.p.A. were the defendants whose agreement was at issue in the sealing request.
What happened
In CT Espresso LLC v. Lavazza Premium Coffees Corp., CT Espresso asked to file an unredacted complaint and an exhibit under seal. The complaint described a contract that contained a confidentiality provision, and the defendants agreed that its terms should remain confidential.
CT Espresso argued that publicly filing the unredacted documents would violate that provision and that it needed to discuss the contract to pursue its breach-of-contract claim. The request concerned the public filing of the complaint and Exhibit A, not the merits of the contract dispute.
Judge Vernon S. Broderick denied the request without prejudice because the letter relied only on the contract’s confidentiality provision and did not provide a sufficient basis for sealing. He allowed CT Espresso to renew the request by February 2, 2022, by identifying a legally permissible basis for sealing or proposing appropriate redactions.
The detailed version
- CT Espresso LLC v. Lavazza Premium Coffees Corp. · No. 1:22-cv-00377
- Denise Cote
- Jan. 26, 2022
Background
CT Espresso LLC filed a letter motion asking to seal an unredacted version of its complaint and Exhibit A. The publicly filed complaint had redactions, and CT Espresso said the documents described and reproduced terms of a written agreement between the parties. That agreement included a provision requiring the parties to keep its terms confidential. CT Espresso asserted a breach-of-contract claim and said it needed to reference the agreement’s terms to bring that claim. Counsel for Lavazza Premium Coffees Corp. and Luigi Lavazza S.p.A. consented to the sealing request.
Legal standard
The court explained that sealing a judicial document requires considering whether the document is a judicial document, the strength of the public’s right of access, and whether legitimate interests against disclosure outweigh that access. Protecting confidential business information may support sealing, but a confidentiality agreement by itself is not enough.
Ruling
Judge Vernon S. Broderick denied the application without prejudice. He found that the letter motion cited only the agreement’s confidentiality provision and did not provide a basis for the specific findings required to seal judicial documents. The court permitted CT Espresso to renew its request by February 2, 2022, if it identified a permissible basis for sealing the documents or proposed appropriate redactions. The opinion did not decide the underlying breach-of-contract claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.