Signify Holding B.V. v. Fohse Inc.
- Gregory Woods
- 1:23-cv-09649
- U.S. District Court · Southern District of New York
- 3
In Signify Holding B.V. v. Fohse Inc., Judge Woods granted in part and denied in part the parties’ motion to seal their settlement agreement.
Signify Holding B.V. and Fohse Inc. must file a public version of their settlement agreement. They may redact permitted bank account information, but the payment schedule must remain visible to the public.
What happened
Signify Holding B.V. and Fohse Inc. asked the court to seal their settlement agreement, which they submitted with a request for judgment under Federal Rule of Civil Procedure 68. They sought to redact bank account information and the payment schedule.
The court found that the settlement agreement was a court document subject to a presumption of public access. It concluded that privacy concerns justified redacting the bank account information, but the payment schedule was important to enforcing the proposed judgment and the parties had not shown a sufficient reason to keep it secret.
Judge Gregory H. Woods granted in part and denied in part the motion to seal. The parties may redact bank account information as allowed by the federal rules, but they must leave the payment schedule unredacted in a new public version filed by April 11, 2024.
The detailed version
- Signify Holding B.V. v. Fohse Inc. · No. 1:23-cv-09649
- Gregory Woods
- Apr. 9, 2024
Background
The parties filed a motion to seal their settlement agreement. They had submitted the agreement in connection with a request for the court to enter judgment under Federal Rule of Civil Procedure 68. The parties asked to redact bank account information and the settlement’s payment schedule. The proposed judgment stated that Signify Holding B.V. would recover $1,400,000 from Fohse Inc. under the settlement agreement.
Legal standard
The court explained that court documents generally carry a presumption of public access. A document is a “judicial document” when the parties submit it to the court and it is relevant and useful to the judicial process. The court must then weigh the public’s interest in access against legitimate reasons for confidentiality, including privacy interests.
Court’s analysis
The court determined that the settlement agreement was a judicial document because it was filed in support of the request for entry of judgment. The court gave relatively little weight to public access concerning the bank account information because that information was not a substantive settlement term and did not affect whether the court would enter judgment. Privacy concerns also supported withholding it. Federal Rule of Civil Procedure 5.2 permits redacting all but the last four digits of a bank account number.
The court gave greater weight to public access concerning the payment schedule. The schedule was incorporated into the proposed judgment, so it had to be discernible for the judgment to be enforced. The parties argued that the information could give competitors valuable insight into their business practices, but the court found that they had not explained how the settlement’s payment schedule would do so.
Ruling
Judge Gregory H. Woods granted in part and denied in part the motion to seal. The request to redact bank account information was granted. The request to redact the payment schedule was denied. The parties were ordered to file another public version of the settlement agreement by April 11, 2024; that version may redact bank account information only to the extent Rule 5.2 allows and must not redact the payment schedule. The Clerk of Court was directed to terminate the motion at Docket No. 29.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.