Medidata Solutions, Inc. v. Veeva Systems Inc.

Background

The parties filed motions to seal documents connected to pretrial motions and related filings. At the court’s direction, the plaintiffs filed an omnibus amended motion to seal. The plaintiffs withdrew some earlier sealing requests, identified documents they believed should remain under seal, explained the basis for confidential treatment, and filed redacted versions of the documents covered by their requests.

The plaintiffs opposed the defendant’s requests to seal information about the amount of stock granted to an employee. They argued that this information was publicly available in Securities and Exchange Commission filings and on the defendant’s website.

Court’s analysis

The court applied the three-part test for sealing judicial documents. First, it determined whether the documents were relevant to the judicial function and therefore subject to a presumption of public access. Second, if the presumption applied, it assessed the strength of that presumption based on the documents’ role in the exercise of federal judicial power. Third, it balanced public access against competing considerations, including privacy and business interests.

The court held that the moving papers were judicial documents subject to the presumption of public access. It found that the presumption was low in weight because the parties had provided redacted versions that omitted only confidential business information and trade secrets. The court concluded that the parties’ competitive business interests outweighed the public interest in access to the redacted information. It also found that the proposed withholding was narrowly tailored to protect proprietary confidential information while preserving public access to the remaining material.

Order

The court ordered the plaintiffs to file, by March 8, 2022, public versions of documents for which they had withdrawn their sealing motions and redacted versions of documents for which they continued to seek confidential treatment.

The court separately ordered the defendant, by March 8, 2022, to file a letter addressing whether the proposed redactions concerning employee stock grants were publicly available, whether more limited redactions could protect confidential information, and how disclosure would damage or embarrass the defendant’s business or the employees.

The court ordered the parties, by March 11, 2022, to coordinate the filing of public, redacted versions of expert reports or excerpts previously filed entirely under seal, or to explain why limited redactions could not protect the confidential information. The Clerk was directed to terminate the sealing motions listed in the order. The opinion does not state that the court resolved the underlying claims between the parties.