Google LLC v. Sonos, Inc.

District Court, N.D. California·Decided February 9, 2024·No. 3:20-cv-06754·Unknown

Opinion

NORTHERN DISTRICT OF CALIFORNIA

Plaintiff, No. C 20-06754 WHA No. C 21-07559 WHA v.

GOOGLE LLC, OMNIBUS ORDER RE FINAL MOTIONS TO SEAL Defendant.

This omnibus order addresses the remaining omnibus motions to seal (Dkt. Nos. 831, 851). In accordance with prior orders, the parties have tailored their requests to seal considerably (see Dkt. Nos. 817, 846). At this stage, the requests largely involve many different filings of the same documents, and they have been granted at a higher rate than in past sealing orders (see Dkt. Nos. 334, 518). The Court again thanks Sonos and its counsel for the careful work narrowing its sealing requests (see Dkt. No. 846 at 1). For the reasons stated herein, Sonos’s omnibus motion to seal is GRANTED. The Court now thanks Google and its counsel for further narrowing its sealing requests and providing detailed charts (see Dkt. Nos. 852–54). For the reasons stated herein, Google’s omnibus motion to seal is GRANTED IN PART and DENIED IN PART. There is a strong public policy in favor of openness in our court system and the public is entitled to know to whom we are providing relief (or not). See Kamakana v. City & Cnty. of attachments that are “more than tangentially related to the merits of a case” may be sealed only upon a showing of “compelling reasons” for sealing. Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1101–02 (9th Cir. 2016). Filings that are only tangentially related to the merits may be sealed upon a lesser showing of “good cause.” Id. at 1097. The compelling reasons standard applies to most judicial records. Evidentiary motions, such as motions in limine and Daubert motions, can be strongly correlative to the merits of a case. Id. at 1098– 1100. In addition, sealing motions filed in this district must contain a specific statement that explains: (1) the legitimate private or public interests that warrant sealing; (2) the injury that will result should sealing be denied; and (3) why a less restrictive alternative to sealing is not sufficient. The material requested to be sealed must be “narrowly tailored to seal only the sealable material.” Civ. L.R. 79-5(c). For example, “[t]he publication of materials that could result in infringement upon trade secrets has long been considered a factor that would overcome [the] strong presumption” in favor of access and provide compelling reasons for sealing. Apple Inc. v. Psystar Corp., 658 F.3d 1150, 1162 (9th Cir. 2011). Compelling reasons may also warrant sealing for “sources of business information that might harm a litigant’s competitive standing,” especially where the public has “minimal interest” in the information. See Nixon v. Warner Comms., Inc., 435 U.S. 589, 598 (1978). Finally, “[s]upporting declarations may not rely on vague boilerplate language or nebulous assertions of potential harm but must explain with particularity why any document or portion thereof remains sealable under the applicable legal standard.” Bronson v. Samsung Elecs. Am., Inc., 2019 WL 7810811, at *1 (N.D. Cal. May 28, 2019) (citing Civ. L.R. 79-5). “Reference to a stipulation or protective order that allows a party to designate certain documents as confidential is not sufficient to establish that a document, or portions thereof, are sealable.” Civ. L.R. 79-5(c). 1. SONOS’S OMNIBUS MOTION TO SEAL (DKT. NO. 831). Regarding Sonos’s omnibus motion and related exhibits, this order rules as follows: Dkt. Document to be Result Reasoning No. Sealed 831-4 Proposed GRANTED. Sonos seeks to seal the proposed term Term Sheet sheet containing the details of a licensing agreement that the parties explored but did not execute prior to this litigation. Google seeks to seal this document as well (see, e.g., Dkt. No. 854-3).

As Sonos observes, solely the existence of this proposed term sheet was discussed in open court at trial, not its details (see Tr. 1038:6–1039:5). According to Sonos, “the parties were only able to consider a pre-litigation license agreement because of the understanding that those negotiations would be confidential, subject to an NDA, and subject to the restrictions on use imposed by Federal Rule of Evidence 408” (Dkt. No. 831 at 4).

Critically, the proposed term sheet was, at most, only tangentially related to the merits of this action. What’s more, its disclosure could foreseeably cause the parties competitive harm and chill others from engaging in negotiations that could avoid such costly and prolonged litigation in other circumstances. 831-5 Proposed GRANTED. See entry for Dkt. No. 831-4. Term Sheet 831-6 Excerpt of GRANTED. Both parties seek to seal material from Bakewell Rebuttal this expert report excerpt. For rulings on Expert Report the additional material that Google seeks to seal, please refer to the entry for Dkt. No. 854-5.

The material that Sonos seeks to seal, in blue boxing, is narrowly tailored and references confidential details of the proposed term sheet, which can be sealed for the reasons stated in the entry on the proposed term sheet above. See entry for Dkt. No. 831-4. 831-7 Google’s Response GRANTED. The material that Sonos seeks to seal is to Sonos’s First narrowly tailored and references Motion in Limine confidential details of the proposed term sheet, which can be sealed for the reasons stated in the entry on the proposed term sheet above. See entry for Dkt. No. 831-4.

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Related

Nixon v. Warner Communications, Inc.
435 U.S. 589 (Supreme Court, 1978)
Apple Inc. v. Psystar Corp.
658 F.3d 1150 (Ninth Circuit, 2011)
Center for Auto Safety v. Chrysler Group, LLC
809 F.3d 1092 (Ninth Circuit, 2016)