Vinci Brands LLC v. Coach Services, Inc.
- Lorna Schofield
- 1:23-cv-05138
- U.S. District Court · Southern District of New York
- 5
In Vinci Brands v. Coach Services, Judge Schofield denied most sealing motions without prejudice, allowed narrow exceptions, and kept filings sealed temporarily.
Vinci Brands LLC, Kate Spade LLC, Coach Services, Inc., and the public. The parties had to justify any continued sealing, renew their motions, or file unredacted documents, while the public’s access to court filings was protected except for approved narrow redactions and documents.
What happened
In Vinci Brands LLC v. Coach Services, Inc. and the related Kate Spade LLC cases, the parties asked to keep documents filed with their complaints and requests for emergency court orders confidential. The documents included termination notices, correspondence, licensing information, financial information, and business details.
The court said these filings are judicial documents, so the public has a strong right to inspect them. The parties did not provide enough specific evidence that most of the information was commercially sensitive. The court found that narrow redactions for licensing fees, the Siena loan amount, production timelines, and information about manufacturers, suppliers, and distributors could protect against competitive harm.
Judge Schofield denied specified sealing motions without prejudice, except that she granted protection for the license agreement and amendments and the listed narrow redactions. She denied other motions because the requested relief had been changed in later motions, granted Vinci’s motion at Docket 47, and ordered all currently sealed documents to remain sealed temporarily. The parties had to renew their motions or file unredacted documents by October 11, 2023.
The detailed version
- Vinci Brands LLC v. Coach Services, Inc. · No. 1:23-cv-05138
- Lorna Schofield
- Sept. 27, 2023
Background
Vinci Brands LLC filed five motions to seal documents connected to its amended complaint and the parties’ cross-motions for a temporary restraining order and preliminary injunction in Case No. 23 Civ. 5138. Kate Spade LLC and Coach Services, Inc., referred to together as KSNY in the order, filed nine motions to seal documents connected to their complaints and related motions in Case No. 23 Civ. 5409. Because the motions raised similar issues, the court addressed them together.
Legal standard
The court applied a three-step test for sealing documents. First, it determined whether a document was a judicial document—that is, a document relevant to the court’s work and useful in the legal process. Second, if the document qualified, the court assessed the strength of the public’s presumed right to access it. Third, the court balanced that presumption against competing interests, including privacy and the protection of sensitive commercial information. A party seeking secrecy bears the burden of showing that those interests outweigh public access.
The court held that the complaints, exhibits, memoranda supporting the emergency motions, and accompanying exhibits were judicial documents. Because they were used in connection with the court’s consideration of the parties’ legal rights, they carried a strong presumption of public access. Contractual confidentiality provisions alone did not overcome that presumption.
Ruling
The court found that the parties had not sufficiently explained why information such as termination notices and letters between the parties was commercially sensitive. The court also noted that the substance of the termination notices appeared in the court’s preliminary-injunction opinion and that general concerns about competitors were not enough to justify sealing.
The court found that proposed redactions for financial information, including licensing fees and the Siena loan amount, production timelines, and information about manufacturers, suppliers, or distributors were narrowly tailored and could protect against competitive harm. It also granted protection for the parties’ license agreement and amendments. The court observed that some information, including the fall 2023 Kate Spade-branded phone-case lineup, appeared to have become stale.
The court ordered that the motions at Dockets 12, 33, 52, 65, 98, and 106 in Case No. 23 Civ. 5138 and Dockets 5, 26, and 54 in Case No. 23 Civ. 5409 were DENIED without prejudice to renewal, except that they were GRANTED as to the license agreement and amendments and the specified proposed redactions. The motions at Dockets 80 and 92 in Case No. 23 Civ. 5138 and Dockets 30 and 39 in Case No. 23 Civ. 5409 were DENIED because the movants modified the requested relief in later motions. Vinci’s motion at Docket 47 was GRANTED. All documents then filed under seal were to remain under seal temporarily.
The parties were ordered, by October 11, 2023, either to file renewed motions or to file unredacted versions of the remaining documents on the public docket. Any renewed motion had to group proposed redactions by category, explain the specific business harm from disclosure, and follow the court’s filing and highlighting instructions. The clerk was directed to close the specified motions.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.