Seabury FXOne LLC v. U.S Specialty Insurance Co.
- Edgardo Ramos
- 1:21-cv-00837
- U.S. District Court · Southern District of New York
- 3
In Seabury FXOne v. U.S Specialty, Judge Ramos granted a motion allowing redacted summary-judgment exhibits to protect sensitive commercial information.
The order affects the plaintiffs’ confidential commercial and financial information, U.S. Specialty’s summary-judgment filing, and the public’s access to the unredacted exhibits.
What happened
Seabury FXOne LLC v. U.S Specialty Insurance Co. concerned U.S. Specialty’s request to file redacted exhibits supporting its motion for summary judgment. The exhibits included deposition excerpts and documents from an arbitration, and the redactions covered specific financial information identified as confidential.
The court recognized that summary-judgment exhibits are generally available to the public, but found that the exhibits contained sensitive commercial information, including investment amounts, ownership percentages, revenue, and valuations. The court concluded that protecting those interests justified redacting specific amounts rather than sealing the exhibits entirely.
Judge Ramos granted the motion to seal. The order allowed U.S. Specialty to file redacted versions of Exhibits 1–3, 6, and 8, while leaving the exhibits’ general descriptions and context available to the public.
The detailed version
- Seabury FXOne LLC v. U.S Specialty Insurance Co. · No. 1:21-cv-00837
- Edgardo Ramos
- May 16, 2022
Background
U.S. Specialty asked the court for permission to file redacted copies of Exhibits 1–3, 6, and 8 to its motion for summary judgment. The exhibits included excerpts from a deposition of Plaintiffs’ corporate representative and documents from an arbitration involving Rosario Ingargiola and FXOne, LLC, described in the request as the “Minority Shareholders,” and the plaintiffs. The plaintiffs had designated the materials as confidential under a protective order.
The plaintiffs requested redactions of financial information concerning losses, revenue, financial performance, and valuation. U.S. Specialty incorporated the plaintiffs’ proposed redactions and filed both public redacted copies and unredacted copies under seal.
Court’s Analysis
The court stated that summary-judgment exhibits are “judicial documents,” meaning documents relevant to the court’s decision and therefore subject to a strong presumption of public access. That presumption can be overcome only when sealing or redaction is necessary to protect a higher-value interest and the restriction is narrowly tailored.
The court found that the exhibits contained sensitive commercial information, including specific investment amounts, ownership percentages connected to capital infusions, projected and actual revenue, and entity valuations. It concluded that the plaintiffs’ interest in protecting this information from commercial competitors outweighed the public’s interest in access to the unredacted amounts.
The court also found that the proposed redactions were the least restrictive way to protect the information. The redactions covered specific amounts but did not remove the characterizations or broader context of the financial information. The plaintiffs agreed that none of the exhibits needed to be sealed in full.
Ruling
Judge Edgardo Ramos granted the motion to seal. The order permitted U.S. Specialty to file redacted copies of Exhibits 1–3, 6, and 8 to its motion for summary judgment. The opinion does not state any separate ruling on the underlying summary-judgment motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.