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S.D.N.Y.Procedural orderFiled Mar. 1, 2024

Momentum Funding, LLC v. Nova Funding Corporation

Judge
Rochon
Docket
1:23-cv-09392
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Momentum Funding v. Nova Funding, Judge Rochon granted permission to file limited redacted documents while reserving future sealing decisions.

Who this affects

Momentum Funding, LLC, which was permitted to file redacted copies of certain documents; the court did not decide whether similar redactions would be allowed in future filings.

What happened

Momentum Funding, LLC v. Nova Funding Corporation involved Momentum Funding’s request to file redacted versions of documents supporting its motion for a judgment because the documents contained its revenue figures from 2015 through 2022.

Momentum Funding argued that the revenue information was sensitive business information and that public disclosure could cause competitive harm. The court agreed to allow the proposed limited redactions.

Judge Jennifer L. Rochon granted the motion to file redacted copies of certain documents. She did not decide whether the information could be redacted in future filings.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Momentum Funding, LLC v. Nova Funding Corporation · No. 1:23-cv-09392
Judge
Rochon
Date
Mar. 1, 2024

Background

Momentum Funding, LLC asked for permission to file public redacted copies and sealed unredacted copies of three documents supporting its motion for a default judgment. The proposed redactions covered Momentum Funding’s average annual and monthly revenue from 2015 through 2022.

Momentum Funding argued that this information was sensitive business information and that disclosure could cause competitive harm. It also argued that the redactions were limited.

Court’s Ruling

The court granted Momentum Funding’s motion to file redacted copies of certain documents. It explained that the proposed redactions were limited and that the redacted information played little to no role in the court’s decision on the default-judgment motion, reducing the weight of the public-access interest in those materials.

The court did not decide whether the information should be redacted in future filings. It noted that the public-access presumption is stronger for documents that directly affect a decision or determine the parties’ legal rights.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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