Spectrum Dynamics Medical Limited v. General Electric Company
- Vernon Broderick
- 1:18-cv-11386
- U.S. District Court · Southern District of New York
- 2
In Spectrum Dynamics Medical v. General Electric, Judge Broderick granted Spectrum’s request to seal trade-secret materials and allow limited redactions.
Spectrum Dynamics Medical Limited and General Electric Company, as parties to the sealing request; the ruling concerns public access to specified case filings containing alleged trade-secret and competitively sensitive information.
What happened
Spectrum Dynamics Medical Limited v. General Electric Company involved Spectrum’s request to protect information in its second amended complaint and related exhibits. Spectrum said the materials described alleged trade secrets and identified General Electric patents that allegedly contained them.
Spectrum asked to redact and seal its second amended complaint and Exhibits 20 and 25, and to file Exhibits 2–18 and 28–29 under seal. The request relied on earlier orders allowing similar materials to be sealed or redacted.
Judge Vernon Broderick granted the motion. The order allowed the proposed redactions and permitted the document filed at ECF No. 630 to remain under seal.
The detailed version
- Spectrum Dynamics Medical Limited v. General Electric Company · No. 1:18-cv-11386
- Vernon Broderick
- Feb. 21, 2023
Background
Spectrum Dynamics Medical Limited asked the court to approve redactions and sealing of materials filed with its Second Amended Complaint. The request concerned the complaint, Exhibits 20 and 25, and Exhibits 2–18 and 28–29.
Spectrum stated that the complaint and Exhibits 20 and 25 described trade secrets that it alleged General Electric misappropriated. Those materials also identified General Electric patents by number and other identifying information and referred to specific figures and text that Spectrum alleged disclosed its trade secrets. Exhibits 2–18 and 28 were copies of General Electric patents that Spectrum alleged contained its misappropriated trade secrets. Exhibit 29 was a copy of Spectrum’s Amended Second Supplemental Table of Trade Secrets.
Requests and Prior Orders
Spectrum asked to file its Second Amended Complaint and Exhibits 20 and 25 under seal and in redacted form. It asked to file Exhibits 2–18 and 28–29 under seal. The filing stated that the court had previously allowed similar redactions and sealing involving Spectrum’s First Amended Complaint, Exhibits 20 and 25, its motion for leave to amend, the General Electric patents, and the trade-secrets table.
Spectrum asserted that its proposed redactions were narrowly tailored to protect trade secrets and other competitively sensitive information. The request cited the Second Circuit’s decision in Lugosch v. Pyramid Co. of Onondaga and related authority.
Ruling
Judge Vernon Broderick granted the motion. The order stated that the proposed redactions were narrowly tailored and that the document filed at ECF No. 630 could remain under seal. The opinion text does not separately describe the treatment of each requested exhibit beyond the stated sealing and redaction request and the order granting the motion.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.