Solid 21, Inc. v. Richemont North America, Inc.
- Subramanian
- 1:19-cv-01262
- U.S. District Court · Southern District of New York
- 2
In Solid 21 v. Richemont, Judge Subramanian denied Defendants’ motion to seal Exhibit B and related redactions because it contained no confidential information.
The ruling affected Solid 21, Inc. and Defendants Richemont North America, Inc., Richemont International S.A., and Montblanc-Simplo GmbH, because Exhibit B was not kept under seal and the requested memorandum redactions were not approved.
What happened
Solid 21, Inc. v. Richemont North America, Inc. involved Defendants’ request to keep Exhibit B under seal and to publicly file a redacted legal memorandum. Defendants said Exhibit B had been designated by Solid 21 as highly confidential under the parties’ protective order.
The court explained that court records generally carry a strong presumption of public access. It found that Exhibit B did not contain trade secrets or other confidential information that would cause a competitive disadvantage if disclosed.
Judge Arun Subramanian denied Defendants’ motion to seal and directed the Clerk of Court to terminate the motion at ECF No. 220.
The detailed version
- Solid 21, Inc. v. Richemont North America, Inc. · No. 1:19-cv-01262
- Subramanian
- Sept. 11, 2023
Background
Defendants Richemont North America, Inc., Richemont International S.A., and Montblanc-Simplo GmbH asked to publicly file a redacted version of their memorandum supporting a motion to strike Solid 21, Inc.’s jury demand. They also asked to file Exhibit B to the supporting declaration under seal. Defendants said Solid 21 had designated Exhibit B “Highly Confidential — Attorneys’ Eyes Only” under the parties’ protective order, and that the memorandum quoted from the exhibit.
Legal standard and analysis
The court stated that judicial documents are subject to a strong common-law presumption of public access. The parties’ protective order allowed a party to designate documents as “Attorneys’ Eyes Only” when the party, acting in good faith, believed the documents contained trade secrets or other confidential information whose disclosure to competitors would cause a competitive disadvantage. The court found that, despite Solid 21’s designation, Exhibit B did not contain such information. Because of the presumption of public access, the court found no reason to keep Exhibit B sealed.
Ruling
Judge Arun Subramanian denied Defendants’ motion to seal. The Clerk of Court was directed to terminate the motion at ECF No. 220.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.