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S.D.N.Y.Procedural orderFiled Aug. 30, 2022

The Sanborn Library LLC v. ERIS Information Inc.

Judge
Ona Wang
Docket
1:19-cv-02049
Court
U.S. District Court · Southern District of New York
Pages
3
Civil ProcedureDiscovery
In one sentence

In The Sanborn Library v. ERIS Information, Judge Wang granted a request to seal materials supporting a motion to compel.

Who this affects

ERIS, The Sanborn Library LLC, Environmental Data Resources, LLC, ProQuest LLC, and other third parties whose confidential materials were included in the specified filings.

What happened

The Sanborn Library LLC and Environmental Data Resources, LLC consented to ERIS’s request to seal parts of a motion to compel allegedly privileged documents and supporting exhibits.

The materials included deposition testimony, privilege logs, business records, communications with the Federal Trade Commission, settlement communications, and documents involving ProQuest. ERIS said the materials contained confidential business information and private third-party information whose disclosure could cause competitive harm.

Judge Ona T. Wang granted the application and directed the Clerk of Court to close docket entry 158. The order did not decide the underlying motion to compel or the parties’ claims.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
The Sanborn Library LLC v. ERIS Information Inc. · No. 1:19-cv-02049
Judge
Ona Wang
Date
Aug. 30, 2022

Background

ERIS Information Inc., ERIS Limited Partnership, and Eco Log Environmental Risk Information Services Ltd. asked the court for permission to file under seal portions of ERIS’s memorandum supporting its motion to compel production of allegedly privileged documents, along with specified exhibits to Justin A. MacLean’s supporting declaration. The request concerned materials filed in support of a non-dispositive motion, meaning a motion that did not resolve the case.

The request covered portions of EDR’s privilege logs; deposition testimony from EDR and ERIS witnesses; emails, presentations, and other documents concerning business affairs, copyright research, marketing and sales strategy, internal litigation preparations, and business decisions; communications with the Federal Trade Commission concerning its investigation into EDR’s acquisition of FirstSearch; materials involving ProQuest LLC; and correspondence concerning settlement discussions. The filing stated that EDR, ERIS, and ProQuest had designated the materials as confidential or highly confidential under the protective order.

Parties’ Positions

ERIS argued that the materials contained commercially sensitive information whose disclosure could cause competitive injury. It also relied on the privacy interests of ProQuest and other third parties. ERIS stated that its request was narrowly limited to documents and testimony referenced in the motion and to portions of the memorandum that necessarily discussed confidential information. The filing stated that Sanborn Library LLC and Environmental Data Resources, LLC consented to the request.

Ruling

Judge Ona T. Wang granted the application. The Clerk of Court was directed to close docket entry 158. The opinion does not state that the court decided the motion to compel, whether any documents were privileged, or the merits of the parties’ underlying dispute.

Classification

This is a procedural order because it resolved a request to seal court materials and did not decide the underlying claims or the motion to compel.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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