iTalent Corporation v. Kotha

• Court: District Court, N.D. California
• Decided: September 17, 2025
• Docket: 5:25-cv-06365
• Status: Unknown

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 iTALENT CORPORATION, Case No. 25-cv-06365-BLF

8 Plaintiff, ORDER GRANTING IN PART AND 9 v. DENYING IN PART PLAINTIFF'S ADMINISTRATIVE MOTION TO 10 RAJU KOTHA, et al., SEAL 11 Defendants. [Re: ECF No. 11]

13 14 Before the Court is Plaintiff iTalent Corporation’s Administrative Motion to Seal. ECF 15 No. 11 (“Mot.”). For the reasons that follow, the Court GRANTS IN PART and DENIES IN 16 PART Plaintiff’s administrative motion. 17 I. LEGAL STANDARD 18 “Historically, courts have recognized a ‘general right to inspect and copy public records 19 and documents, including judicial records and documents.’” Kamakana v. City & Cnty. of 20 Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (quoting Nixon v. Warner Commc’ns, Inc., 435 21 U.S. 589, 597 & n.7 (1978)). Consequently, access to motions and their attachments that are 22 “more than tangentially related to the merits of a case” may be sealed only upon a showing of 23 “compelling reasons” for sealing. Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 24 1101–02 (9th Cir. 2016). Filings that are only tangentially related to the merits may be sealed 25 upon a lesser showing of “good cause.” Id. at 1097. 26 In addition, in this district, all parties requesting sealing must comply with Civil Local 27 Rule 79-5. That rule requires, inter alia, the moving party to provide “the reasons for keeping a 1 warrant sealing; (ii) the injury that will result if sealing is denied; and (iii) why a less restrictive 2 alternative to sealing is not sufficient.” Civ. L.R. 79-5(c)(1). Civil Local Rule 79-5 requires the 3 moving party to provide “evidentiary support from declarations where necessary.” Civ. L.R. 79- 4 5(c)(2). And the proposed order must be “narrowly tailored to seal only the sealable material.” 5 Civ. L.R. 79-5(c)(3). 6 II. DISCUSSION 7 Plaintiff iTalent Corporation (“itD”) seeks to seal several exhibits attached to its 8 Application for a Temporary Restraining Order. Mot. at 1. None of the Defendants submitted any 9 response. 10 itD asserts that material it seeks to seal pertains to “granular details of the confidential 11 financial information” of its projects and “business development communications with its 12 customers and potential customers.” Id. itD argues that the information it seeks to seal is 13 comprised of the company’s “financial lifeblood” and “key business development” information. 14 Id. at 2. The disclosure of this information, itD argues, will lead to irreparable injury. Id. at 2–3. 15 As the sealing request relates to an application for a temporary restraining order, which the 16 Court finds is “more than tangentially related to the underlying cause[s] of action,” the Court will 17 apply the “compelling reasons” standard. Ctr. for Auto Safety, 809 F.3d at 1099–101. 18 The “compelling reasons” standard is met for confidential business information, including 19 financial records, that would harm a party’s competitive standing. See Day v. GEICO Cas. Co., 20 No. 21-cv-02103-BLF, 2023 WL 5955795, at *2 (N.D. Cal. Aug. 30, 2023) (finding compelling 21 reasons to seal “non-public financial information” because its release would “threaten . . . 22 competitive interests”); Jam Cellars, Inc. v. Wine Grp. LLC, No. 19-cv-01878-HSG, 2020 WL 23 5576346, at *2 (N.D. Cal. Sept. 17, 2020) (finding compelling reasons for sealing “confidential 24 business and proprietary information”); Fed. Trade Comm’n v. Qualcomm Inc., No. 17-cv-00220- 25 LHK, 2019 WL 95922, at *3 (N.D. Cal. Jan. 3, 2019) (finding compelling reasons to seal 26 “information that, if published, may harm . . . competitive standing and divulges terms of 27 confidential contracts, contract negotiations, or trade secrets”); In re Elec. Arts, Inc., 298 F. App’x 1 competitive standing”). Accordingly, the Court finds that itD has demonstrated compelling 2 reasons to seal certain exhibits comprised of financial material, as indicated below in the chart. 3 With respect to those exhibits, the Court also finds that the request is narrowly tailored. See Civ. 4 L.R. 79-5(c)(3). 5 The Court finds that itD has not demonstrated compelling reasons to seal the remaining 6 documents. ECF No. 11-11 appears to be an email thread listing an employee’s daily task 7 completion list, which was filed with client names already redacted. Yet itD does not explain how 8 the release of this exhibit—which it seeks to seal entirely—would reveal any confidential or 9 sensitive information, let alone “jeopardiz[e] plaintiff’s competitiveness in the market.” Mot. at 1. 10 ECF Nos. 11-12, 11-13, and 11-14 are all also pre-redacted correspondence that seem to reveal no 11 sensitive financial or client information or business development strategies. itD does not explain 12 why the release of any portion of these documents would harm its competitive standing. 13 Furthermore, the Court finds that even if compelling reasons exist to seal some portions of these 14 documents, the requests are not narrowly tailored. See Civ. L.R. 79-5(c)(3). 15 The Court’s ruling is summarized below: 16 ECF No. Document Portion(s) Requested to Seal Ruling 17 11-6 Ex. A to Declaration Entire document. GRANTED as containing of Renee La Londe confidential financial 18 (“La Londe Decl.”) information. 19 20 11-7 Ex. B to La Londe Entire document. GRANTED as containing Decl. confidential financial 21 information. 11-11 Ex. F to La Londe Entire document. DENIED as overbroad. 22 Decl. 23 24 11-12 Ex. G to La Londe Entire document. DENIED as overbroad. 25 Decl. 26 27 I 11-13 Ex. H toLaLonde | Entire document. DENIED as overbroad. Decl. 2 3 11-14 Ex. I to La Londe Entire document. DENIED as overbroad. 4 Decl. 5 6 7 Il. ORDER 8 For the foregoing reasons, IT IS HEREBY ORDERED that Plaintiff's Administrative g || Motion to Seal, ECF No. 11, is GRANTED IN PART AND DENIED IN PART. 10 All denials are WITHOUT PREJUDICE. Any refiled administrative motion or declaration 11 SHALL be filed no later than September 29, 2025. Plaintiff SHALL refile public versions of

= 12 each filing where the redactions and sealing granted by the Court are narrower than what was 5 13 redacted in the current public versions by September 29, 2025, unless it is filing a renewed

14. || sealing motion for any document in that filing.

15 IT IS SO ORDERED. Q 16

= 17 1g || Dated: September 17, 2025 19 BETH LABSON FREEMAN 20 United States District Judge 21 22 23 24 25 26 27 28