Binh Thanh Import Export Production & Trade Joint Stock Co. v. Amazon.com…

Background

The plaintiff asked that exhibits at Dkt. 58 be filed under seal because of the parties’ confidentiality designations. Amazon separately asked the court to redact certain information from the public record and file unredacted versions under seal. Amazon described the information as highly confidential, competitively sensitive, and proprietary trade information concerning technologies used in its fulfillment centers and its supply-chain strategy.

Legal standard

The court stated that court records are subject to a strong common-law presumption of public access. That presumption is not absolute, however, and the court must balance public access against competing interests. The court noted that confidentiality designations alone do not decide whether documents should be sealed or redacted, but that courts routinely protect commercially sensitive information and confidential business and financial information. When disclosure of confidential business information could cause competitive harm, the court said there can be a compelling justification for sealing the material.

Ruling

The court found that Amazon had shown that the material it sought to redact contained sensitive information that could harm its competitive standing. The court therefore ordered that Amazon’s requests to redact certain information from the public record, with unredacted versions filed under seal, were granted. The Clerk was directed to maintain the documents at Dkts. 58, 61, 63, 67, and 69 under seal and to close the motions at Dkts. 57, 62, and 66. The order does not separately state a disposition for the plaintiff’s request to seal the exhibits at Dkt. 58.