Rodo Inc. v. Guimaraes
- Vernon Broderick
- 1:22-cv-09736
- U.S. District Court · Southern District of New York
- 3
In Rodo Inc. v. Guimaraes, Judge Broderick granted Rodo’s request to redact confidential business information from a hearing transcript.
Rodo Inc. may file the hearing transcript with the proposed redactions, including redactions concerning its confidential financial information. Talles Guimaraes’s objection was rejected, and the order also affects Ari Cohen as a defendant involved in the underlying hearing.
What happened
Rodo Inc. v. Guimaraes concerned proposed redactions to a transcript of a hearing about Rodo’s request for a temporary restraining order against Talles Guimaraes and Ari Cohen. Rodo said some transcript passages contained confidential business information.
The court found the proposed redactions reasonable, limited, and focused on confidential information about Rodo’s profitability and financial condition. The court also addressed Guimaraes’s objection, interpreting it as challenging the redaction on page 26 because the page and line reference in his filing appeared inconsistent.
Judge Vernon S. Broderick granted Rodo’s motion and request to file the transcript with its proposed redactions. The order directed Rodo to file the redacted transcript by December 9, 2023, and directed the Clerk of Court to terminate the motion.
The detailed version
- Rodo Inc. v. Guimaraes · No. 1:22-cv-09736
- Vernon Broderick
- Dec. 5, 2022
Background
The parties disputed proposed redactions to the transcript of a November 18, 2022 hearing concerning Rodo Inc.’s request for a temporary restraining order against Talles Guimaraes and Ari Cohen. Before the hearing, the court sent Rodo questions it expected to discuss. Rodo answered most of them in a filing but said that several questions involved sensitive business information that it would ask the court to seal. During the hearing, Rodo requested redactions to transcript portions discussing that information. The court initially sealed the transcript and allowed the parties to propose redactions.
Rodo proposed redactions on November 29, 2022. Guimaraes opposed one redaction. The opinion notes that Guimaraes identified page 23, lines 13–14, while Rodo’s filing stated that he opposed a redaction on page 26, lines 13–14. Because there was no single sentence at the page 23 location and a partial redaction there would make little sense, the court interpreted Guimaraes’s objection as addressing page 26, lines 13–14.
Legal standard
The court treated the transcript as a judicial document: a filed item relevant to the court’s work and useful in the judicial process. Materials submitted to help decide a request for a temporary restraining order or preliminary injunction receive the highest presumption of public access. That presumption can be overcome for confidential commercial information, including information about a business’s operations and financial condition. Any sealing or redaction must be narrowly tailored, meaning it must conceal only information that needs protection.
Court’s ruling
The court held that the contested redaction concerned confidential information directly related to the profitability of Rodo, which the court described as a privately held start-up company. The proposed redaction covered only one sentence on page 26, lines 13–14, rather than sealing the entire transcript. The court found that redaction, as well as the other uncontested proposed redactions, appropriate under the applicable standard.
Judge Vernon S. Broderick therefore GRANTED Rodo’s motion and GRANTED Rodo’s request to file the transcript with its proposed redactions. The court directed Rodo to file the transcript by December 9, 2023, and directed the Clerk of Court to terminate the motion at Document 33. This order addressed the transcript redactions rather than the underlying request for a temporary restraining order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.