Seabury FXOne LLC v. U.S Specialty Insurance Co.
- Edgardo Ramos
- 1:21-cv-00837
- U.S. District Court · Southern District of New York
- 4
In Seabury FXOne v. U.S. Specialty, Judge Ramos granted Seabury’s request to file redacted summary-judgment exhibits protecting sensitive commercial information.
Seabury and the public’s access to exhibits filed in the case were affected. Seabury was allowed to protect specified sensitive commercial information through redactions, while the public retained access to the remaining portions of the exhibits.
What happened
In Seabury FXOne LLC v. U.S. Specialty Insurance Co., Seabury asked to file partially redacted exhibits supporting its motion for summary judgment and opposing U.S. Specialty’s motion.
The exhibits contained financial information, ownership details, valuations, client and competitor names, and references to confidential expert reports from an arbitration. Seabury argued that the information was commercially sensitive, unrelated to the pending motions, and could be protected through limited redactions rather than complete sealing.
The court granted the request to file redacted documents. Judge Edgardo Ramos found that Seabury’s commercial interests outweighed the public’s access interests and that the proposed redactions were narrowly tailored; the order did not decide the summary-judgment motions.
The detailed version
- Seabury FXOne LLC v. U.S Specialty Insurance Co. · No. 1:21-cv-00837
- Edgardo Ramos
- June 10, 2022
Background
Seabury FXOne LLC, Seabury Asset Management LLC, and Seabury International Capital Holdings LLC, collectively referred to in the opinion as “Seabury,” requested permission to file partially redacted copies of exhibits supporting Seabury’s cross-motion for summary judgment and opposing U.S. Specialty Insurance Co.’s motion for summary judgment. The documents had been designated as confidential discovery material under a protective order.
The requested redactions covered exhibits including correspondence, emails, arbitration filings and transcripts, deposition excerpts, interrogatory responses, and the arbitrator’s decision. Seabury said the documents contained sensitive commercial information, including financial losses, revenues, projections, capital contributions, financial performance, valuations, ownership holdings, and client, customer, and competitor names. Seabury also sought to remove references to expert reports that had been designated confidential in the arbitration.
Court’s Analysis
The opinion explained that filing a document with the court does not automatically make it a public judicial document. A document is subject to the public-access right when it is relevant to the court’s work and useful in the judicial process. Any sealing or redaction must be supported by specific findings, protect an important interest, and be narrowly tailored.
The court concluded that the exhibits contained sensitive commercial information, including investment amounts, ownership percentages tied to capital contributions, projected and actual revenue, and entity valuations. Protecting that information served Seabury’s commercial interests, and those interests outweighed the public’s right of access. The court also found that the proposed redactions were the least restrictive means of protection because they removed specific amounts while leaving characterizations and context available to the public. The exhibits did not need to be filed entirely under seal.
Disposition
The court granted Seabury’s request to file redacted copies of the identified exhibits. Judge Edgardo Ramos entered the order on June 10, 2022. The opinion addressed only the filing of redacted documents and did not state a ruling on either party’s motion for summary judgment.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.