Adstra, LLC v. Kinesso, LLC

District Court, S.D. New York·Decided March 31, 2025·No. 1:24-cv-02639·Unknown

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: Sanne KK DATE FILED:_03/31/2025 ADSTRA, LLC, : Plaintiff, : : 24-cv-2639 (LJL) -v- : : MEMORANDUM AND KINESSO, LLC, & ACXIOM, LLC, : ORDER Defendants. :

LEWIS J. LIMAN, United States District Judge: By order of February 21, 2025, the Court directed the parties to file letters addressing which of the documents filed under seal in connections with the motions to seal at Dkt. Nos. 87, 99, 113, 115, 139, 157, 180, 189, and 199 required continued sealing in light of the Court’s Opinion and Order at Dkt. No. 203. Each party filed such a letter. Dkt. Nos. 206-207. The Court construes these letters as motions to seal and addresses them here. The motions are granted in part and denied in part. I. Legal Framework There is a presumption of public access to judicial documents. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006); Brown v. Maxwell, 929 F.3d 41, 47-48 (2d Cir. 2019). A judicial document is a document “relevant to the performance of the judicial function and useful in the judicial process.” Brown, 929 F.3d at 49 (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I’)). “[A]l| documents submitted in connection with, and relevant to, such judicial decision-making are subject to at least some presumption of public access.” Jd. at 50. However, “the presumption of public access in filings

submitted in connection with discovery disputes or motions in limine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions.” Id. This is because a Court’s “authority to oversee discovery and control the evidence introduced at trial . . . is ancillary to the court's core role in adjudicating a case.” Id.

If a presumptive right of public access exists, “the proponent of [sealing] must establish through ‘specific, on the record findings . . . that [sealing] is essential to preserve higher values and is narrowly tailored to serve that interest.” Courthouse News Serv. v. Corsones, 2025 WL 758028, at *4 (2d Cir. Mar. 11, 2025) (quoting Press-Enterprise Co. v. Superior Court of California for Riverside County, 478 U.S. 1, 13–14 (1986)). “Courts have found that higher values include protecting the confidentiality of grand jury proceedings, protecting minor victims of sex crimes, protecting a defendant's Sixth Amendment right to a fair trial, protecting significant and substantial privacy interests . . . preventing danger to persons or property, and maintaining the integrity of significant activities entitled to confidentiality, such as ongoing undercover investigations or detection devices.” Id. (citation omitted).

Courts have also frequently held that protection of confidential commercial information and trade secrets may overcome the presumption of public access, as the right of access to the courts would be compromised if, as a condition of that access, a party was forced to disclose the very secrets that it was trying to protect. See, e.g., Standard Inv. Chartered, Inc. v. Fin. Indus. Regul. Auth., Ind., 347 F. App’x 615–617 (2d Cir. 2009); Bergen Brunswig Corp. v. Ivax Corp., 1998 WL 113976, at *3 (S.D.N.Y. Mar. 12, 1998); Louis Vuitton Malletier S.A. v. Sunny Merch. Corp., 97 F. Supp. 3d 485, 510–511 (S.D.N.Y. 2015). In determining whether such information is properly sealed, courts may look to whether “the information [is] still relevant to the business” and “the degree to which a party would be competitively harmed if [the information] were revealed.” Jackpocket, Inc. v. Lottomatrix NY LLC, 2022 WL 17738779, at *2 (S.D.N.Y. Dec. 15, 2022) (quotation marks and citation omitted). II. Defendants’ Motion for Continued Sealing Defendants’ motion for continued sealing addresses three sets of documents. Dkt. No.

207. Defendants first seek continued sealing of a set of documents, identified in Appendix A to their motion, submitted in connection with motions for summary judgment. Id. at 2–3. For many documents in this category, Defendants seek to unseal portions of the document with limited redactions of confidential business information and the personally identifiable information of third parties. Id. “[I]t is well-settled that ‘documents submitted to a court for its consideration in a summary judgment motion are—as a matter of law—judicial documents to which a strong presumption of access attaches.’” Brown, 929 F.3d at 47 (quoting Lugosch, 435 F.3d at 121). Defendants argue that for this set of documents, the presumption is overcome by the countervailing harm that would occur from the disclosure of confidential business information and trade secrets. Dkt. No. 207 at 2–3.

The Court has individually reviewed each document. See Lugosch, 435 F.3d at 116. For the vast majority of the documents in Appendix A which Defendants seek to maintain under seal, the Court agrees with Defendants that the presumption of public access is overcome by the countervailing interest in protection of confidential commercial information and trade secrets. The proposed targeted redactions of confidential information and personally identifiable information are “narrowly tailored to serve that interest.” Courthouse News Serv., 2025 WL 758028, at *4. The Court grants Defendants’ motion with regards to all documents in Appendix A except Dkt. Nos. 134-1, 134-5, and 134-7. The redacted information in these three deposition transcripts plays a significant role in the Court’s Opinion and Order of February 21, 2025, and the “value of such information to those monitoring the federal courts” outweighs any remaining confidentiality interest. Brown, 929 F.3d at 49 (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”). Those documents will be unsealed in full. Defendants next seek continued sealing of certain documents submitted in connections

with motions rendered moot by the grant of summary judgment to Defendants, listed in Exhibit B to Defendants’ letter-motion. Dkt. No. 207 at 3–4, App’x B. Defendants argue that because the motions were rendered moot, these are not “judicial documents” subject to the presumption of public access. Id. This conclusion is not convincing. The Second Circuit has noted that a document is “‘relevant to the performance of the judicial function’ if it would reasonably have the tendency to influence a district court's ruling on a motion or in the exercise of its supervisory powers, without regard to which way the court ultimately rules or whether the document ultimately in fact influences the court's decision.” Brown, 929 F.3d at 49 (quoting Amodeo I, 44 F.3d at 145–46). Here, at least some documents submitted in connection with the moot motions, such as the reports of the parties’ experts, were clearly relevant to the Court’s decision that the motions were in fact moot.1 In addition, the Second Circuit has recently reaffirmed that the

presumption is one of “immediate public access.” Courthouse News Serv., 2025 WL 758028, at *5 (quoting Lugosch, 435 F.3d at 126). The documents clearly were judicial documents at the time they were filed, and it would be inconsistent with Circuit precedent for them to lose this status due to the way the court “ultimately rule[d].” Brown, 929 F.3d at 49.

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Related

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71 F.3d 1044 (Second Circuit, 1995)
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United States v. Amodeo
44 F.3d 141 (Second Circuit, 1995)
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97 F. Supp. 3d 485 (S.D. New York, 2015)