Prism Data Technologies, Inc. v. TomoCredit, Inc.

District Court, S.D. California·Decided February 20, 2026·No. 3:24-cv-02300·Unknown

Opinion

PRISM DATA TECHNOLOGIES, INC., Case No.: 24-cv-2300-RSH-MMP

Plaintiff, ORDER (1) DENYING MOTIONS TO v. SEAL AND (2) DENYING REQUEST TO FILE SURREPLY

Defendant. [ECF Nos. 47, 49, 53, 55, 57]

Pending before the Court are: (1) motions to seal filed by the Parties in connection with briefing on the motion by plaintiff Prism Data Technologies, Inc. (“Prism”) to enforce a settlement agreement; and (2) a motion by defendant TomoCredit, Inc. (“Tomo”) for leave to file a sur-reply in opposition to that same motion to enforce. As set forth below, the Court denies the motions. On December 10, 2024, Prism filed this lawsuit against Tomo, bringing claims for trademark infringement and unfair competition. ECF No. 1. On February 10, 2025, Tomo filed its answer. ECF No. 6. On April 17, 2025, Tomo filed an amended answer with counterclaims seeking cancellation of Prism’s trademark registration and a declaration that the mark is invalid. ECF No. 17. Prism moved to dismiss the counterclaims. ECF No. 21. The Parties thereafter engaged in extensive settlement discussions before U.S. Magistrate Judge Michelle M. Pettit. On June 2, 2025, Judge Pettit advised by minute order that “[o]n May 23, 2025, the Court held a continued Early Neutral Evaluation (ENE) followed by the delivery of a mediator’s proposal that was accepted by all parties by the May 30, 2025 deadline. The Parties are now in the process of finalizing their settlement.” ECF No. 28. On July 30, 2025, Judge Pettit further advised that the Parties “have requested a conference regarding disagreement of the settlement terms discussed at the Court’s Early Neutral Evaluation.” ECF No. 32. Following numerous further conferences, Judge Pettit set a scheduling order for Prism to file a motion to enforce a settlement agreement. ECF No. 40. On January 16, 2026, Prism filed its motion to enforce. ECF No. 46. Tomo timely filed a response, and Prism a reply. ECF Nos. 51, 52. On February 19, 2026, Tomo filed a motion requesting leave to file a sur-reply, attaching a copy of the proposed sur-reply brief. ECF No. 57. In connection with each of the four briefs, the Parties have filed motions to seal. ECF Nos. 47, 49, 53, 55. The first of these motions to seal, filed by Prism, seeks to redact references to or discussion of the terms of the alleged settlement agreement, on the grounds that the “public disclosure of the terms … could result in injury to Prism by unilaterally constituting a breach of the agreement and, potentially, orders of the Court.” ECF No. 47 at 5-6. Prism acknowledged the strong presumption in favor of access to public records, and stated that the redacted material did not contain trade secrets. Id. at 6. Prism further stated that “while it has no interest in breaching promises it made to the defendant and the Court, or violating instructions expressly stated on transcripts, the documents should be filed under seal only either: unless and until (1) the defendant in this action sufficiently explains why and to what extent they should remain sealed; or (2) the Court determines sua sponte that the documents subject to this Application should be filed publicly and in full in light of the presumptive right of public access to court records.” Id. at 7. Tomo did not respond to Prism’s motion to seal, but filed its own motion to seal in connection with its opposition brief to Prism’s motion to enforce. ECF No. 49. Tomo’s motion to seal sought to redact similar material, citing the confidentiality term, and urging that “public disclosure of the terms contained therein could result in injury to the parties by making it impossible later to enter into a settlement agreement whose terms are confidential.” Id. at 6. Tomo further noted that the information under seal relates to the proceedings of early neutral evaluation conferences that, as provided Civil Local Rule 16.1(c)(1)(B), “will be informal, off the record, privileged, and confidential.” Id. Tomo argued that “[i]t would undermine the policy of this Court with respect to the ENE procedure if transcripts and documents exchanged pursuant to the proceedings of an ENE were made available in a public filing.” Id. The Parties’ subsequent motions to seal—filed by Prism in connection with its reply brief, and by Tomo in connection with its motion for leave to file a sur-reply brief— advanced the same rationales as those previously offered by each Party. ECF Nos. 53, 55. Courts have historically recognized a “general right to inspect and copy public records and documents, including judicial records.” Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 597 & n.7 (1978). “Unless a particular court record is one ‘traditionally kept secret,’ a ‘strong presumption in favor of access’ is the starting point.” Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (quoting Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003)). “The presumption of access is ‘based on the need for federal courts, although independent—indeed, particularly because they are independent—to have a measure of accountability and for the public to have confidence in the administration of justice.’” Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1096 (9th Cir. 2016) (quoting United States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995)). To overcome this presumption of access, a party must show either “good cause” or “compelling reasons” to seal a record, depending on the motion to which the record relates. Id. at 1096-97. The Ninth Circuit has made it “clear that public access to filed motions and their attachments does not merely depend on whether the motion is technically ‘dispositive.’” Id. at 1100–01 (“[O]ur circuit looks past the literal dispositive/nondispositive label.”). “Rather, public access will turn on whether the motion is more than tangentially related to the merits of a case.” Id. If the motion is “more than tangentially related to the merits of a case,” the movant must show “compelling reasons” for overcoming the presumption in favor of public access. Id. at 1096-99. Otherwise, a party need only show good cause. Id.; see, e.g., Baker v. SeaWorld Ent., Inc., No. 14-cv- 2129-MMA-AGS, 2017 WL 5029612, at *2 (S.D. Cal. Nov. 3, 2017). “[T]he ‘compelling reasons standard applies to most judicial records.’” Ctr. for Auto Safety, 809 F.3d at 1098 (quoting Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–78 (9th Cir. 2010)). Here, the Parties are in agreement that the “compelling reasons” standard applies to Prism’s motion to enforce the settlement agreement. See ECF No. 47 at 6 (Prism’s motion to seal); ECF No. 49 at 3 (Tomo’s motion to seal). “Under this stringent standard, a court may seal records only when it finds ‘a compelling reason and articulate[s] the factual basis for its ruling, without relying on hypothesis or conjecture.’” Ctr. for Auto Safety, 809 F.3d at 1096-97 (alteration in original) (quoting Kamakana, 447 F.3d at 1179). “The mere fact that the production of records may lead to a litigant’s embarrassment, incrimination, or exposure to further litigation will not, without more, compel the court to seal its records.” Kamakana, 447 F.3d at 1180 (citing Foltz, 331 F.3d at 1136). Once a party articulates their compelling reasons, “[t]he court must then ‘conscientiously balance[ ] the competing interests of the public and the party who seeks to keep certain judicial records secret.’” Ctr. for Auto Safety, 809 F.3d at 1097 (alteration in original) (quoting Kamakana, 447 F.3d at 1179). “What constitutes a ‘compelling reason’ is ‘best left to the sound

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Prism Data Technologies, Inc. v. TomoCredit, Inc., (S.D. Cal. 2026).

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