The Sanborn Library LLC v. ERIS Information Inc.
- Ona Wang
- 1:19-cv-02049
- U.S. District Court · Southern District of New York
- 3
In The Sanborn Library v. ERIS Information, Judge Wang granted an application to seal confidential business and third-party materials filed with a discovery-related motion.
The ruling affects Sanborn Library LLC, Environmental Data Resources, LLC, ERIS Information Inc., Eco Log Environmental Risk Information Services Ltd., ERIS Information Limited Partnership, ProQuest LLC, and other third parties whose confidential business information appeared in the materials. It limits public access to the specified materials by granting the application to seal.
What happened
In The Sanborn Library LLC v. ERIS Information Inc., EDR asked to seal parts of its opposition to ERIS’s request for privileged documents and several supporting exhibits. EDR had publicly filed a redacted version and submitted an unredacted version to the court.
The materials included deposition testimony, emails, memoranda, interrogatory responses, and a spreadsheet. The request stated that the materials contained commercially sensitive information about EDR, ERIS, ProQuest LLC, and other business relationships, and that disclosure could cause competitive harm or reveal private third-party information.
The court granted the application and directed the clerk to close docket entry 167. Judge Ona T. Wang did not decide the underlying dispute or the discovery motion in this order.
The detailed version
- The Sanborn Library LLC v. ERIS Information Inc. · No. 1:19-cv-02049
- Ona Wang
- Aug. 30, 2022
Background
Plaintiff and counterclaim-defendants Sanborn Library LLC and Environmental Data Resources, LLC, referred to collectively as EDR, requested permission to file portions of EDR’s opposition to ERIS’s motion to compel production of privileged documents under seal. EDR also sought to seal or redact accompanying exhibits. The request was made with the consent of defendants and counterclaim-plaintiffs ERIS Information Inc., Eco Log Environmental Risk Information Services Ltd., and ERIS Information Limited Partnership, referred to collectively as ERIS.
EDR stated that it had publicly filed a redacted version of the opposition and submitted an unredacted version. The materials included deposition testimony from EDR, ERIS, and ProQuest LLC witnesses; emails, memoranda, and other produced documents; ERIS’s responses to interrogatories; and a spreadsheet listing copyrighted Sanborn Maps and corresponding ERIS orders.
Reasons for Sealing
The request identified the materials as containing commercially sensitive information, including business practices, market and product strategies, acquisition information, customer information, order numbers, confidential business relationships, internal procedures, and discussions of legal advice. EDR also stated that some materials contained private information concerning ProQuest and other non-parties. According to the request, disclosure could cause competitive injury to EDR, ERIS, ProQuest, or other third parties.
The request relied on Second Circuit decisions concerning the public’s right of access to court records, narrow tailoring of sealing requests, and the privacy interests of innocent third parties. It also stated that the materials supported a non-dispositive motion and were not pleadings.
Ruling
The court granted the application. It directed the clerk to close ECF 167. The order addressed sealing and redaction of materials; it did not resolve the parties’ underlying claims, counterclaims, or ERIS’s motion to compel.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.