Kate Spade LLC v. Vinci Brands LLC

Background

This order addresses sealing motions in two related cases: Vinci Brands LLC v. Coach Services, Inc., No. 23 Civ. 5138, and Kate Spade LLC, et al. v. Vinci Brands LLC, et al., No. 23 Civ. 5409. Vinci filed five motions to seal documents connected with its amended complaint and the parties’ cross-motions for a temporary restraining order and preliminary injunction. Kate Spade and Coach Services, referred to together as KSNY, filed nine sealing motions connected with their complaints and the parties’ cross-motions for emergency relief. The court considered the motions together because they raised similar issues and arguments.

Legal standard

The court applied a three-step test for sealing court documents. First, it asked whether the material was a judicial document—material relevant to the court’s work and useful in the legal process. Second, if the material qualified, it assessed the strength of the public’s presumptive right to access it. Third, it balanced that right against competing interests, including privacy and protection of sensitive commercial information. The party seeking secrecy bears the burden of showing that a higher value outweighs public access. Any sealing must be supported by specific findings and must be narrowly tailored.

The court held that the exhibits to the complaints, the parties’ briefs, and the exhibits supporting the temporary restraining-order and preliminary-injunction motions were judicial documents. Because those materials were important to understanding the court’s decisions about the parties’ legal rights, the presumption of public access was strong. The court rejected the parties’ reliance on the license agreement’s confidentiality clause alone and found that vague concerns about possible competitive harm were insufficient. The parties had not provided enough factual support to justify sealing termination notices and correspondence, among other materials.

Rulings

The court found that proposed redactions for financial information, including licensing fees and the Siena loan amount, as well as production timelines and information about manufacturers, suppliers, or distributors, were narrowly tailored and justified by protection against competitive harm. The court also granted the requested treatment for the license agreement and its amendments. It noted that some information, including the fall 2023 lineup of Kate Spade-branded phone cases, appeared commercially stale. The court stated that the parties’ explanations were often insufficient to seal entire documents, except for the license agreement and its amendments.

The court ordered that the motions at Dkts. 12, 33, 52, 65, 98, and 106 in Case No. 23 Civ. 5138 and Dkts. 5, 26, and 54 in Case No. 23 Civ. 5409 were DENIED without prejudice to renewal, except that they were GRANTED to the extent described for the license agreement and amendments and the specified financial and business-information redactions. The motions at Dkts. 80 and 92 in Case No. 23 Civ. 5138 and Dkts. 30 and 39 in Case No. 23 Civ. 5409 were DENIED because the movant later modified the requested relief. Vinci’s motion at Dkt. 47 was GRANTED.

All documents then filed under seal were to remain sealed temporarily. By October 11, 2023, the parties had to file renewed motions or place unredacted versions of the remaining documents on the public docket. Any renewed motion had to group the proposed redactions by category, explain the business harm from disclosure, and follow the court’s filing and highlighting requirements. The clerk was directed to close the specified motions.