Catala v. Joombas Co LTD

Background

Juan Catala, doing business as Majic Entertainment LLC and Adrawn Music Publishing, sued Hyuk Shin; Joombas Co. Ltd., Joombas Music International, Joombas LLC, and Joombas Music Group; and the LA Reid Music Publishing Company LLC, EMI April Music Inc., and Sony/ATV Songs LLC. The complaint asserted claims involving contracts, fiduciary duties, fraud, interference with contractual relations, copyright, and an accounting. The claims arose from agreements concerning rights to musical compositions authored by Shin.

The court had previously granted the Joombas Defendants’ and Reid Defendants’ motions to dismiss and had granted in part and denied in part Shin’s motion to dismiss. Catala and Shin later filed cross-motions for summary judgment. Two submissions supporting Catala’s motion, together totaling nearly 800 pages, were filed under seal without an explanation and without a motion requesting permission to seal them.

Sealing standards

The court’s individual rules require a sealing request to be narrowly tailored to the purpose asserted to justify sealing and to address the presumption that the public may access judicial documents. The court cited the required analysis for sealed judicial documents, including determining whether the materials are judicial documents, assessing the weight of the public-access presumption, and balancing competing considerations. The court also stated that party consent to sealing, or the existence of a protective order, does not by itself establish that sealing is appropriate.

Ruling

Judge Paul G. Gardephe ordered that the documents then under seal would be unsealed on August 2, 2023, unless a motion to seal was filed. Any motion had to address the applicable public-access factors and propose sealing narrowly tailored to serve the asserted justification. The order addressed the sealed filings; it did not rule on the parties’ cross-motions for summary judgment.