Palo Alto Networks, Inc. v. Taasera Licensing LLC

Background

Palo Alto Networks filed an action asserting declaratory-judgment claims, including claims concerning non-infringement. Quest Patent Research Corporation asked for permission to file under seal an unredacted version of its reply memorandum supporting its motion to dismiss for lack of subject-matter jurisdiction or, alternatively, failure to state a claim.

Request to Seal

Quest’s request stated that the reply described confidential business and agreement information. Quest represented that the publicly filed versions would contain redactions and that filing an unsealed, unredacted version could disclose the information publicly and violate confidentiality provisions. The request also stated that Palo Alto Networks could be prejudiced if it could not reference the information when pursuing its declaratory-judgment claims.

The request discussed the usual sealing factors: whether the document is a judicial document, the strength of the public-access presumption, and whether legitimate interests against disclosure outweigh that presumption. It identified protecting confidential business information as an interest that can weigh against disclosure.

Ruling

The court granted Quest Patent Research Corporation’s request for permission to file under seal the unredacted version of its reply in support of its motion to dismiss. The order did not decide the underlying motion to dismiss.