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

CourtDistrict Court, S.D. California
DecidedFebruary 20, 2026
Docket3:24-cv-02300
StatusUnknown

This text of Prism Data Technologies, Inc. v. TomoCredit, Inc. (Prism Data Technologies, Inc. v. TomoCredit, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 PRISM DATA TECHNOLOGIES, INC., Case No.: 24-cv-2300-RSH-MMP

12 Plaintiff, ORDER (1) DENYING MOTIONS TO 13 v. SEAL AND (2) DENYING REQUEST TO FILE SURREPLY 14 TOMOCREDIT, INC.,

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

16 17 18 Pending before the Court are: (1) motions to seal filed by the Parties in connection 19 with briefing on the motion by plaintiff Prism Data Technologies, Inc. (“Prism”) to enforce 20 a settlement agreement; and (2) a motion by defendant TomoCredit, Inc. (“Tomo”) for 21 leave to file a sur-reply in opposition to that same motion to enforce. As set forth below, 22 the Court denies the motions. 23 I. BACKGROUND 24 On December 10, 2024, Prism filed this lawsuit against Tomo, bringing claims for 25 trademark infringement and unfair competition. ECF No. 1. On February 10, 2025, Tomo 26 filed its answer. ECF No. 6. On April 17, 2025, Tomo filed an amended answer with 27 counterclaims seeking cancellation of Prism’s trademark registration and a declaration that 28 the mark is invalid. ECF No. 17. Prism moved to dismiss the counterclaims. ECF No. 21. 1 The Parties thereafter engaged in extensive settlement discussions before U.S. 2 Magistrate Judge Michelle M. Pettit. On June 2, 2025, Judge Pettit advised by minute order 3 that “[o]n May 23, 2025, the Court held a continued Early Neutral Evaluation (ENE) 4 followed by the delivery of a mediator’s proposal that was accepted by all parties by the 5 May 30, 2025 deadline. The Parties are now in the process of finalizing their settlement.” 6 ECF No. 28. On July 30, 2025, Judge Pettit further advised that the Parties “have requested 7 a conference regarding disagreement of the settlement terms discussed at the Court’s Early 8 Neutral Evaluation.” ECF No. 32. Following numerous further conferences, Judge Pettit 9 set a scheduling order for Prism to file a motion to enforce a settlement agreement. ECF 10 No. 40. 11 On January 16, 2026, Prism filed its motion to enforce. ECF No. 46. Tomo timely 12 filed a response, and Prism a reply. ECF Nos. 51, 52. On February 19, 2026, Tomo filed a 13 motion requesting leave to file a sur-reply, attaching a copy of the proposed sur-reply brief. 14 ECF No. 57. 15 In connection with each of the four briefs, the Parties have filed motions to seal. ECF 16 Nos. 47, 49, 53, 55. The first of these motions to seal, filed by Prism, seeks to redact 17 references to or discussion of the terms of the alleged settlement agreement, on the grounds 18 that the “public disclosure of the terms … could result in injury to Prism by unilaterally 19 constituting a breach of the agreement and, potentially, orders of the Court.” ECF No. 47 20 at 5-6. Prism acknowledged the strong presumption in favor of access to public records, 21 and stated that the redacted material did not contain trade secrets. Id. at 6. Prism further 22 stated that “while it has no interest in breaching promises it made to the defendant and the 23 Court, or violating instructions expressly stated on transcripts, the documents should be 24 filed under seal only either: unless and until (1) the defendant in this action sufficiently 25 explains why and to what extent they should remain sealed; or (2) the Court determines 26 sua sponte that the documents subject to this Application should be filed publicly and in 27 full in light of the presumptive right of public access to court records.” Id. at 7. 28 1 Tomo did not respond to Prism’s motion to seal, but filed its own motion to seal in 2 connection with its opposition brief to Prism’s motion to enforce. ECF No. 49. Tomo’s 3 motion to seal sought to redact similar material, citing the confidentiality term, and urging 4 that “public disclosure of the terms contained therein could result in injury to the parties 5 by making it impossible later to enter into a settlement agreement whose terms are 6 confidential.” Id. at 6. Tomo further noted that the information under seal relates to the 7 proceedings of early neutral evaluation conferences that, as provided Civil Local Rule 8 16.1(c)(1)(B), “will be informal, off the record, privileged, and confidential.” Id. Tomo 9 argued that “[i]t would undermine the policy of this Court with respect to the ENE 10 procedure if transcripts and documents exchanged pursuant to the proceedings of an ENE 11 were made available in a public filing.” Id. 12 The Parties’ subsequent motions to seal—filed by Prism in connection with its reply 13 brief, and by Tomo in connection with its motion for leave to file a sur-reply brief— 14 advanced the same rationales as those previously offered by each Party. ECF Nos. 53, 55. 15 II. MOTIONS TO SEAL 16 Courts have historically recognized a “general right to inspect and copy public 17 records and documents, including judicial records.” Nixon v. Warner Commc’ns, Inc., 435 18 U.S. 589, 597 & n.7 (1978). “Unless a particular court record is one ‘traditionally kept 19 secret,’ a ‘strong presumption in favor of access’ is the starting point.” Kamakana v. City 20 & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (quoting Foltz v. State Farm 21 Mut. Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003)). “The presumption of access is 22 ‘based on the need for federal courts, although independent—indeed, particularly because 23 they are independent—to have a measure of accountability and for the public to have 24 confidence in the administration of justice.’” Ctr. for Auto Safety v. Chrysler Grp., LLC, 25 809 F.3d 1092, 1096 (9th Cir. 2016) (quoting United States v. Amodeo, 71 F.3d 1044, 1048 26 (2d Cir. 1995)). 27 To overcome this presumption of access, a party must show either “good cause” or 28 “compelling reasons” to seal a record, depending on the motion to which the record relates. 1 Id. at 1096-97. The Ninth Circuit has made it “clear that public access to filed motions and 2 their attachments does not merely depend on whether the motion is technically 3 ‘dispositive.’” Id. at 1100–01 (“[O]ur circuit looks past the literal 4 dispositive/nondispositive label.”). “Rather, public access will turn on whether the motion 5 is more than tangentially related to the merits of a case.” Id. If the motion is “more than 6 tangentially related to the merits of a case,” the movant must show “compelling reasons” 7 for overcoming the presumption in favor of public access. Id. at 1096-99. Otherwise, a 8 party need only show good cause. Id.; see, e.g., Baker v. SeaWorld Ent., Inc., No. 14-cv- 9 2129-MMA-AGS, 2017 WL 5029612, at *2 (S.D. Cal. Nov. 3, 2017). “[T]he ‘compelling 10 reasons standard applies to most judicial records.’” Ctr. for Auto Safety, 809 F.3d at 1098 11 (quoting Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–78 (9th Cir. 2010)). 12 Here, the Parties are in agreement that the “compelling reasons” standard applies to 13 Prism’s motion to enforce the settlement agreement. See ECF No. 47 at 6 (Prism’s motion 14 to seal); ECF No. 49 at 3 (Tomo’s motion to seal). “Under this stringent standard, a court 15 may seal records only when it finds ‘a compelling reason and articulate[s] the factual basis 16 for its ruling, without relying on hypothesis or conjecture.’” Ctr. for Auto Safety, 809 F.3d 17 at 1096-97 (alteration in original) (quoting Kamakana, 447 F.3d at 1179).

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Prism Data Technologies, Inc. v. TomoCredit, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/prism-data-technologies-inc-v-tomocredit-inc-casd-2026.