Araujo v. E. Mishan & Sons, Inc.

Background

William Araujo moved to seal the court’s earlier Opinion and Order construing two terms in one of his patent claims. At the court’s direction, he submitted a supporting brief on September 30, 2022. The court treated the request as a motion to seal a judicial document.

Legal standard

The court explained that the First Amendment and common law create a presumption that the public may access judicial records. Courts apply a three-step inquiry: they determine whether the material is a judicial document, assess the strength of the access presumption, and then balance that presumption against legitimate reasons for secrecy.

Araujo conceded that the Opinion was a judicial document. The court therefore found that the presumption of public access applied. It also held that the presumption was strong because the document was a judicial decision and because its discussion of claim-construction standards and analysis could help litigants and judges in future cases.

Arguments and analysis

Araujo argued that the presumption was weak because the case was a private civil dispute that had not attracted media attention. The court rejected that argument, explaining that the lack of media attention did not reduce the Opinion’s role in the court’s exercise of judicial power.

Araujo also argued that the public Opinion could make it harder for him to bring new infringement actions against other defendants and could harm settlement possibilities if those defendants could read it. The court held that these concerns did not provide a compelling reason for sealing. It emphasized that the Opinion had already been available on the public docket and electronic research platforms for more than three months.

Disposition

The court denied Araujo’s motion to seal the Claim Construction Opinion and Order. It directed the Clerk of Court to close Docket Number 95. The order addressed access to the judicial document and did not decide the underlying patent dispute in this order.