Precision Medicine Group, LLC v. Blue Matter, LLC
- Paul Gardephe
- 1:20-cv-02974
- U.S. District Court · Southern District of New York
- 4
Precision Medicine v. Blue Matter: Judge Gardephe denied without prejudice the parties’ sealing motions and required narrower, individualized requests.
The parties to the case, including Precision Medicine Group, LLC and Blue Matter, LLC, and any parties or nonparties whose confidential information was included in the proposed filings.
What happened
In Precision Medicine Group, LLC v. Blue Matter, LLC, the parties asked to seal or redact more than 1,200 pages filed with their summary-judgment motions, citing confidential, client-related, and trade-secret information.
The court said the requests did not analyze each document individually or show that the proposed sealing was narrowly tailored to protect an important interest. It denied the sealing motions without prejudice and required renewed motions organized by category, supported by specific legal authority, and presented in a format the court could practically review.
Judge Paul G. Gardephe directed the parties to file renewed sealing motions by February 28, 2023, and directed the clerk to terminate the motions at Docket Nos. 146 and 169.
The detailed version
- Precision Medicine Group, LLC v. Blue Matter, LLC · No. 1:20-cv-02974
- Paul Gardephe
- Feb. 14, 2023
Background
In connection with the parties’ motions for summary judgment, the parties asked to file substantial portions of their papers under seal or in redacted form. The plaintiffs sought to seal exhibits attached to their statements of material facts and said they would file more than 35 additional exhibits under seal or with redactions at the request of Blue Matter and former defendants Naina and Jose Jauregui. Blue Matter sought sealing or redaction of documents, deposition transcripts, and references in the parties’ briefing and factual statements to confidential information, including its customers’ names. In total, the parties proposed sealing or redacting more than 1,200 pages.
Legal standard
The court applied the standard from Lugosch v. Pyramid Co. of Onondaga and related cases. Under that standard, a party seeking to seal material filed with a pending motion must justify sealing each document individually, show that closure is essential to protect a higher value, and demonstrate that the proposed sealing or redaction is narrowly tailored to that interest.
Ruling
The court held that the parties’ motions made only passing references to the applicable standard and did not provide the required individualized analysis. Assertions that the material was highly confidential, involved trade secrets, or related to clients were not enough by themselves. The court therefore denied the pending sealing motions without prejudice.
The court ordered that any renewed motion be filed by February 28, 2023, comply with the Lugosch standard, and present proposed redactions in a format practical for review. It directed the parties to organize documents into categories based on the higher value asserted to justify sealing or redaction, identify each document by its individual Electronic Case Filing docket number, and support each category with relevant case law. Requests made at the direction of another party or a nonparty also had to be justified under Lugosch and related cases. The clerk was directed to terminate the motions at Docket Nos. 146 and 169.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.