In re Google Play Consumer Antitrust Litigation

CourtDistrict Court, N.D. California
DecidedAugust 25, 2021
Docket3:20-cv-05761
StatusUnknown

This text of In re Google Play Consumer Antitrust Litigation (In re Google Play Consumer Antitrust Litigation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Google Play Consumer Antitrust Litigation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 In re Google Play Store Antitrust Litigation Case No. 21-md-02981-JD

8 ORDER RE MOTION TO STAY AND 9 RENEWED APPLICATION TO SEAL 10 11

12 In a prior order, the Court denied the Google defendants’ request to seal portions of the 13 four complaints, which would have limited the public’s right of access to the court proceedings in 14 this high-profile multidistrict antitrust litigation. Dkt. No. 79. The reasons for the denial were 15 straightforward. “[J]udicial records are public documents almost by definition, and the public is 16 entitled to access by default.” Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180 17 (9th Cir. 2006) (citation omitted); see also Center for Auto Safety v. Chrysler Group, LLC, 809 18 F.3d 1092, 1096 (9th Cir. 2016) (when considering a request to seal, “we start with a strong 19 presumption in favor of access to court records.”) (quotation omitted). As the party seeking to seal 20 the complaints, Google had “the burden of overcoming this strong presumption by meeting the 21 ‘compelling reasons’ standard.” Kamakana, 447 F.3d at 1178 (quoting Foltz v. State Farm Mut. 22 Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003)); see also Center for Auto Safety, 809 F.3d at 23 1098 (our precedent presumes that the “‘compelling reasons’ standard applies to most judicial 24 records.”) (quoting Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009)) 25 (emphasis added in Center for Auto Safety). 26 To seal portions of the complaints -- the documents that are the heart of this, and every, 27 lawsuit -- Google was required to “articulate compelling reasons supported by specific factual 1 Kamakana, 447 F.3d at 1178-79 (cleaned up); see also Pintos, 605 F.3d at 678-79 (same); 2 Johnstech Int’l Corp. v. JF Microtechnology SDN BHD, No. 14-cv-02864-JD, 2016 WL 4091388, 3 at *1 (N.D. Cal. Aug. 2, 2016) (party must provide “specific, individualized reasons for the 4 sealing”). Conclusory statements by a party about potential harm from public disclosure, or mere 5 hypothesis or conjecture, will not do. Kamakana, 447 F.3d at 1179; Hagestad v. Tragesser, 49 6 F.3d 1430, 1434 (9th Cir. 1995). The fact that the parties may have designated a document as 7 confidential under a stipulated protective order is also not enough to justify sealing. “Such blanket 8 orders” are inherently overbroad and do not provide the “particularized showing” required to seal 9 any individual court record. See San Jose Mercury News, Inc. v. United States District Court, 187 10 F.3d 1096, 1103 (9th Cir. 1999). In addition, different interests are at stake with the right of 11 access to court records than with the production of documents during discovery. See Kamakana, 12 447 F.3d at 1180. 13 Google had an ample opportunity to demonstrate a compelling reason for sealing, and 14 squandered it. The governing standards summarized here have been well-established for many 15 years, and our District’s local rules clearly state the procedures for Google to follow in making its 16 case. See Civil L.R. 79-5. Even so, Google presented nothing but generic and boilerplate 17 statements for its sealing requests. It gestured at its internal confidentiality practices as a ground 18 for sealing, which was nothing more than an ipse dixit rationale. See Dkt. No. 79 at 2. It 19 mentioned the protective orders entered in the litigation as a basis, but that carried little weight. 20 See id and supra. The “factual showing” it proffered was a declaration by a “Senior Legal Project 21 Manager” at Google stating that the disclosure of “non-public information” could, “[i]f revealed to 22 competitors and potential business counterparties, . . . disadvantage Google in marketing and in 23 negotiations.” Dkt. No. 74-1. This was literally all Google said with respect to meeting the 24 requirement of a specific factual demonstration of a compelling reason, and it repeated the same 25 statement over 140 times in the declaration, without any further commentary or evidence. Id. 26 Overall, Google made no showing whatsoever that might have favored keeping portions of the 27 complaints secret, and its “failure to meet that burden means that the default posture of public 1 Consequently, Google’s sealing requests were denied. Dkt. No. 79. Pursuant to Civil 2 Local Rule 79-5(f), the Court directed the plaintiff groups to file unredacted versions of their 3 respective complaints on ECF within 7 days of the order, namely by August 25, 2021. Id. at 3. 4 Epic beat that deadline and filed its unredacted complaint on August 19, 2021. Dkt. Nos. 81, 82. 5 The other three plaintiff groups apparently agreed to hold off on filing their unredacted complaints 6 at Google’s request. Dkt. No. 84-1 ¶¶ 8-11. On August 20, 2021, Google filed an “Emergency 7 Motion to Stay the Court’s August 18, 2021 Order,” Dkt. No. 83, as well as a “Renewed 8 Application to Seal,” Dkt. No. 85. 9 Google’s request for a do-over is misdirected in several respects. To start, Google cannot 10 credibly claim surprise or lack of a fair chance to address the sealing standards. The salient case 11 law and local rules have been on the books for a good while, and Google is represented here by 12 two top-tier law firms with ample resources to get a proper sealing request on file. In addition, the 13 Court expressly cautioned at a status conference that any requests to keep complaint allegations 14 sealed from the public would be closely scrutinized. See Dkt. No. 67 (“Google is advised that for 15 any portions of the complaints for which Google requests sealing, it will need to make a 16 persuasive showing that sealing is appropriate under the governing standards. Complaints are 17 foundational case documents to which the public has a strong right of access, especially in a case 18 such as this one.”). In these circumstances, Google’s plea for a break because this was the “first 19 sealing exercise” in the litigation, Dkt. No. 85 at 2, is unpersuasive. 20 So too for Google’s effort to pass the buck for its shortfall to the Court. Google hedged its 21 original requests with the statement that “if the Court believes that Google should support its 22 request with either a supplemental declaration or additional detail in support of its sealing request, 23 Google can provide such additional support and requests leave to do so.” Dkt. No. 161 at 2; Dkt. 24 No. 83-1 ¶ 3; Dkt. No. 84-1 ¶ 3. This fundamentally misunderstands federal motion practice. The 25 Court does not review a party’s motion papers and offer coaching pointers for a second round of 26 briefs. The burden is on the party to make its case in the first instance, as it sees fit. That is all the 27 more true in the sealing context, where the “judge need not document compelling reasons to 1 unseal; rather the proponent of sealing bears the burden with respect to sealing.” Kamakana, 447 2 F.3d at 1182. 3 Google is also less than forthright in characterizing the present motion as a “renewed” 4 application. There is no basis for that in the federal procedural rules. In effect, Google seeks 5 reconsideration of the prior order without owning up to the standards that govern reconsideration, 6 starting with the requirement that a party must request leave to file such a motion. See Civil L.R. 7 7-9(a) (“No party may notice a motion for reconsideration without first obtaining leave of Court to 8 file the motion.”). Nor did Google make any effort to demonstrate the existence of new facts or 9 law, or the other circumstances that might warrant reconsideration. See id. 7-9(b).

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In re Google Play Consumer Antitrust Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-google-play-consumer-antitrust-litigation-cand-2021.