CT Espresso LLC v. Lavazza Premium Coffees Corp.

Background

This breach-of-contract action concerns a settlement agreement between CT Espresso LLC and the defendants. On January 26, 2022, the court denied without prejudice an earlier request to file an unredacted complaint and the confidential settlement agreement under seal. The court explained that a confidentiality agreement, by itself, does not justify sealing court records, and invited the parties to renew the request with enough information for specific findings about why sealing was appropriate.

CT Espresso filed a new letter motion on February 2, 2022. The defendants stated that the settlement agreement resolved disputes involving alleged unpaid invoices, alleged trademark infringement, the sale of gray-market goods, dealings with Amazon, and CT Espresso's importation of Lavazza goods into the United States. They argued that public disclosure could put Lavazza at a competitive disadvantage by revealing confidential information about its agreement with another customer concerning its products and intellectual property.

Court's Reasoning

The court found the defendants' explanation insufficient. It described the reasoning as circular and conclusory because it treated the existence of a confidential agreement as equivalent to the kind of disclosure that could create a competitive disadvantage. The defendants did not identify which portions of the agreement would cause competitive harm or explain how disclosure of particular portions would cause that harm. Without that information, the court could not make the specific findings required to seal judicial documents.

Ruling

The request to file the complaint and settlement agreement under seal was again denied without prejudice. The parties could renew the request by filing a letter motion on or before February 11, 2022, but the court said this would be their last opportunity and required a clear explanation supported by case law applicable to the dispute. The court also strongly encouraged the parties to consider publicly filing the unredacted documents or agreeing to arbitrate in a forum without the same public-access rights that apply in a federal court. The Clerk was directed to close the motion at docket number 14. Judge Vernon S. Broderick signed the order.