Columbia Insurance Co. v. Simpson Strong-Tie Company Inc

District Court, N.D. California·Decided July 10, 2025·No. 3:19-cv-04683·Unknown

Opinion

COLUMBIA INSURANCE CO., et al., Case No. 19-cv-04683-TSH

Plaintiffs, ORDER RE: ADMINISTRATIVE v. MOTIONS TO FILE UNDER SEAL

SIMPSON STRONG-TIE COMPANY Re: Dkt. Nos. 140, 147, 157, 183 INC., Defendant. Plaintiffs Columbia Insurance Co. and MiTek Inc. (“Plaintiffs”) filed a complaint for patent infringement against Defendant Simpson Strong-Tie Company Inc. (“Simpson”). ECF No. 61 (First Amended Complaint). Simpson filed a counterclaim for patent invalidity against Plaintiffs. ECF No. 64. Pending before the Court are two administrative motions to file under seal brought by Plaintiffs (ECF Nos. 140, 157) and two administrative motions to file under seal brought by Simpson (ECF Nos. 147, 183). For the reasons set forth below, the Court GRANTS Plaintiffs’ first Motion, GRANTS IN PART and DENIES IN PART Plaintiffs’ second Motion, GRANTS Simpson’s first Motion, and GRANTS Simpson’s second Motion.1 “Historically, courts have recognized a ‘general right to inspect and copy public records and documents, including judicial records and documents.’” Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (quoting Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 597, n.7 (1978)). Courts generally apply a “compelling reasons” standard when considering motions to seal, recognizing that “a strong presumption in favor of access is the starting point.” Id. (cleaned up). Parties seeking to seal judicial records relating to motions that are “more than tangentially related to the underlying cause of action,” Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1099 (9th Cir. 2016), bear the burden of overcoming the presumption with “compelling reasons supported by specific factual findings that outweigh the general history of access and the public policies favoring disclosure,” Kamakana, 447 F.3d at 1178–79 (cleaned up). By contrast, a “good cause showing” under Federal Rule of Civil Procedure 26(c) “will suffice to keep sealed records attached to non-dispositive motions.” Kamakana, 447 F.3d at 1180. Here, the documents at issue in Plaintiffs’ Administrative Motions (ECF Nos. 140, 157) were filed by Plaintiffs in connection with their Motion for Summary Judgment (ECF No. 141) and their Opposition to Simpson’s Motion for Summary Judgment (ECF No. 157-2). Simpson’s second Administrative Motion was filed in connection with its Reply in support of its Motion for Summary Judgment. ECF Nos. 183, 184. Motions for summary judgment, along with their attached documents, are more than tangentially related to the merits of a case. See Ctr. for Auto Safety, 809 F.3d at 1098 (“while discovery-related motions are often unrelated to the merits of a case, the same cannot be said for materials attached to a summary judgment motion because summary judgment adjudicates substantive rights and serves as a substitute for trial”) (cleaned up); Exeltis USA Inc. v. First Databank, Inc., No. 17-cv-04810-HSG, 2020 WL 2838812, at *2 (N.D. Cal. June 01, 2020) (“Because the parties seek to seal portions and documents which pertain to summary judgment motions, the Court applies the compelling reasons standard to these documents.”). Accordingly, the compelling reasons standard applies to Plaintiffs’ administrative motions and to Simpson’s second administrative motion. The documents at issue in Simpson’s first Administrative Motion (ECF No. 147) were filed by Simpson in connection with its Daubert Motion to Exclude (ECF No. 148). Where, as here, a Daubert motion concerns opinions on “invalidity of the patents at issue in the case . . . and efforts to strike or exclude expert opinions,” the compelling reasons standard applies. VLSI Tech. see also Ctr. for Auto Safety, 809 F.3d at 1100 (treating Daubert motion as dispositive because it “pertain[ed] to central issues bearing on defendant's summary judgment motion,” and applying compelling reasons standard to the motion). Accordingly, the compelling reasons standard applies to Simpson’s first administrative motion. Civil Local Rule 79-5 supplements the “compelling reasons” standard. Exeltis, 2020 WL 2838812, at *1. Where, as here, a filing party (the “Filing Party”) seeks to seal a filed document because that document has been designated as confidential by another party (the “Designating Party”), the Filing Party must file an Administrative Motion to Consider Whether Another Party’s Material Should Be Sealed. CIV. L.R. 79-5(f). This motion must identify each document or portions thereof for which sealing is sought. Id. “Within 7 days of the motion's filing, the Designating Party must file a statement and/or declaration” including “a specific statement of the applicable legal standard and the reasons for keeping a document under seal.” Id. at 79-5(c)(1), (f). That statement must include (i) the legitimate private or public interests that warrant sealing; (ii) the injury that will result if sealing is denied; and (iii) why a less restrictive alternative to sealing is not sufficient. Id. at 79-5(c)(1). A failure to file a statement or declaration may result in the unsealing of the provisionally sealed document without notice to the Designating Party. Id. A. ECF No. 140 On May 5, 2025, Plaintiffs filed an Administrative Motion to Consider Whether Another Party’s Material Should Be Sealed, pursuant to Civil Local Rule 79-5, in connection with their Motion for Summary Judgment (“Pl.’s MSJ”). ECF Nos. 141, 140. Plaintiffs move to file portions of one document under seal on the basis that it was designated as “Attorneys’ Eyes Only” by Simpson: Pl.’s MSJ, Ex. J, at 33:6–36:24, 44:20–45:8 (ECF No. 140-2). ECF No. 140. On May 12, 2025, Simpson responded to Plaintiffs’ first Administrative Motion requesting sealing of the portions of Exhibit J identified by Plaintiffs. ECF No. 146. In support of its request, Simpson submits a declaration from Joseph V. Mauch setting forth the bases for sealing the document. See Declaration of Joseph V. Mauch in Support of Plaintiffs’ Administrative Simpson’s Vice President, Sam Hensen—the document discusses Simpson’s confidential business information as it contains non-public information regarding Simpson’s intellectual property and confidential sales data regarding Simpson’s products. Id. at ¶¶ 4–6. The Court has reviewed the requested portions to be sealed and finds Simpson’s requests are narrowly tailored to the confidential business document. The Court agrees that there are compelling reasons to seal the requested portions as they relate to the confidential business document. See Regis Metro Associates, Inc. v. NBR Co., LLC, No. 20-cv-02309-DMR, 2022 WL 267443, at *14 (N.D. Cal. Jan. 28, 2022) (granting motion to seal because “[a]ll of the documents contain sensitive business information or may be subject to confidentiality agreements”); In re Apple Inc. Device Performance Litigation, No. 5:18-md-02827-EJD, 2019 WL 1767158, at *2 (N.D. Cal. Apr. 22, 2019) (noting that under the compelling reasons standard, courts have upheld the sealing of “trade secrets, marketing strategies, product development plans, detailed product specific financial information, customer information, internal reports, and other such materials that would harm a party’s competitive standing”). Accordingly, the Court GRANTS Plaintiffs’ first Administrative Motion and ORDERS that ECF No. 140-2 remain under seal. As the redacted version of Exhibit J has already been filed in the public record (ECF No. 140-3), no further action is required. B. ECF No. 157 On May 30, 2025, Plaintiffs filed a combined Administrative Motion to Consider Whether Another Party’s Material Should Be Sealed and an Administrative Motion to Seal, pursuant to Civil Local Rule 79-5, in connection with their Opposition to Simpson’s Motion for Summary Judgment (“Pl.’s

Free access — add to your briefcase to read the full text and ask questions with AI

Columbia Insurance Co. v. Simpson Strong-Tie Company Inc, (N.D. Cal. 2025).

Columbia Insurance Co. v. Simpson Strong-Tie Company Inc (Columbia Insurance Co. v. Simpson Strong-Tie Company Inc) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

John Archer v. Mary Deneale
26 U.S. 585 (Supreme Court, 1828)
Center for Auto Safety v. Chrysler Group, LLC
809 F.3d 1092 (Ninth Circuit, 2016)