KIN & Company Inc. v. Matte Projects LLC

Background

Matte Projects LLC asked the court to allow redactions in its amended Rule 7.1 disclosure statement. The disclosure statement was required by an earlier court order so the court could determine whether diversity jurisdiction existed. The requested redactions covered the identities of the members of Matte LLC, which the filing described as Matte Projects’ sole member and parent. The states of residence of those members were not subject to the requested redactions.

Matte Projects argued that the members’ identities were not relevant to KIN & Company Inc.’s contract and account-stated claims against Matte Projects, that the information was confidential and not publicly available, and that disclosure could harm nonparties. KIN & Company took no position on the redaction request or on its being filed without notice to the other side. Matte Projects also asked the court to treat the redacted disclosure statement as properly filed and to keep the unredacted version out of the electronic filing system.

Court’s analysis

The court applied the framework for sealing or redacting judicial documents. It determined that Matte Projects had shown interests sufficient to overcome the presumption that court records should be publicly accessible. The court emphasized that the proposed redactions covered only personal information concerning nonparties and were narrowly tailored.

Ruling

Judge Laura Taylor Swain granted the request for redaction. The court found that the scope of the proposed redactions was reasonable and narrowly limited to personal information whose disclosure could injure nonparties to the action. The unredacted Exhibit A must be maintained under seal, with access only by the court and defense counsel. The court stated that the ruling resolved docket entry number 25.