Research America, Inc. v. Peter Simpson et al.

CourtDistrict Court, W.D. New York
DecidedDecember 5, 2025
Docket1:23-cv-00320
StatusUnknown

This text of Research America, Inc. v. Peter Simpson et al. (Research America, Inc. v. Peter Simpson et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Research America, Inc. v. Peter Simpson et al., (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

RESEARCH AMERICA, INC.,

Plaintiff, 23-CV-320-LJV v. DECISION & ORDER

PETER SIMPSON et al.,

Defendants.

On August 5, 2024, the plaintiff, Research America, Inc. (“RAI”), moved to extend the preliminary injunction issued against the defendants, Peter Simpson, Donna Simpson, and Segmedica, Inc., that was set to expire on August 31, 2024. See Docket Item 59. In connection with that motion, RAI sought to seal two supporting exhibits that consist of documents produced by two non-parties, Fresenius and Myovant. See Docket Item 60. After that motion to seal was granted, Docket Item 61, RAI asked to seal two other exhibits filed in connection with its reply in further support of its motion to extend the preliminary injunction, Docket Item 66. Like the exhibits submitted with the first motion to seal, those exhibits consist of documents that were produced during discovery by two non-parties, this time Fresenius and Purdie Pascoe. See id. After more carefully reviewing both sealing motions, the Court concluded that RAI had not given the Court information sufficient to satisfy Local Rule of Civil Procedure 5.3(a), which provides that “documents are [presumptively] publicly accessible” and that “[a] party seeking to have a . . . document[ ] or portion of a document filed under seal bears the burden of demonstrating that such material should be sealed under applicable law.” See Docket Item 74 (quoting Loc. R. Civ. P. 5.3(a)). The Court therefore ordered RAI to show cause why the documents covered by the two motions to seal “should not be unsealed.” Id. In response to that order, RAI narrowed the scope of its sealing requests.

Compare Docket Items 60 and 66 (first and second sealing motions), with Docket Item 79 (RAI’s response to Court’s order to show cause). Instead of seeking to seal all the documents to which its two sealing motions refer, RAI now seeks to keep under seal only parts of two documents filed in support of its motion to extend the preliminary injunction, Docket Items 59-7 and 59-8; parts of another document filed with its reply, Docket Item 65-2; and one other document filed with its reply in its entirety, Docket Item 65-3. See Docket Item 79 at 5.1 More specifically, RAI’s sealing request is now limited to 1) specific pages of a document that contains the defendants’ formal work proposal to perform market research known as the “ATU Wave 4” project for non-party Fresenius, Docket Item 59-7 at FMC000000036-46; 2) specific pages of a document that contains

RAI’s “PersonaSmart questions,” Docket Item 59-8 at SMPA0000346.1-346.3; and 3) two presentations (one in draft form) of a report prepared in connection with that project (the “ATU Wave 4 Report”), Docket Items 65-2 at pages 4-121 (presentation) and 65-3 (draft presentation). See Docket Item 79 at 5, 14.2

1 The Court ultimately denied RAI’s motion to extend the preliminary injunction. Docket Item 80. 2 Page numbers in docket citations refer to ECF pagination. For the reasons that follow, the Court concludes that RAI has shown good cause under the applicable standard, and the sealing of the documents and excerpts identified in its response to this Court’s order is justified.

DISCUSSION Under Local Rule of Civil Procedure 5.3(a), “parties, complaints, and documents

are [presumptively] publicly accessible,” and “[a] party seeking to have a case, party, complaint, document, or portion of a document filed under seal bears the burden of demonstrating that such material should be sealed under applicable law.” That rule is consistent with the longstanding “‘presumption of access’ to judicial records,” which is rooted in the Constitution as well as the common law. Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 141 (2d Cir. 2016) (quoting Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006)); see also United States v. Erie County, 763 F.3d 235, 238-39 (2d Cir. 2014) (“The notion that the public should have access to the proceedings and documents of courts is integral to our system of government.”).

To determine whether a right of access attaches to a filing, the court must first decide whether the record at issue constitutes a “judicial document.” Bernstein, 814 F.3d at 140-41. The Second Circuit has explained that “the mere filing of a paper or document with the court is insufficient to render that paper a judicial document subject to the right of public access”; instead, “the item filed must be relevant to the performance of the judicial function and useful in the judicial process.” United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995). If a court determines that a filing is a “judicial document[ ],” that document may be sealed only “if a sufficiently compelling countervailing interest is demonstrated,” see United States v. King, 2012 WL 2196674, at *1-2 (S.D.N.Y. June 15, 2012) (citing Lugosch, 435 F.3d at 120) (common law standard), and if the court makes “specific, on

the record findings . . . demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest,” id. at *2 (quoting Press-Enter. Co. v. Super. Ct., 478 U.S. 1, 13-14 (1986)) (First Amendment standard). As an initial matter, the Court agrees with RAI’s concession, Docket Item 79 at 7, that the documents in question are judicial in nature and therefore enjoy some presumption of public access. See Sylvania v. Ledvance, 2021 WL 412241, at *1 (S.D.N.Y. Feb. 5, 2021) (concluding that a brief, supporting declarations, and exhibits filed in connection with preliminary injunction motion were “plainly judicial documents”). But it is also true that unlike “[m]aterials submitted in connection with a motion for summary judgment,” which enjoy “a strong presumption of public access[,]” “materials

submitted in connection with . . . non-dispositive motions are subject to a lesser—but still substantial—presumption of public access.” Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Accordingly, the documents RAI asks the Court to keep under seal, materials submitted in connection with a non-dispositive motion to extend a preliminary injunction, enjoy “a lesser—but still substantial—presumption of public access.” See id. RAI argues that countervailing interests overcome that “lesser—but still substantial—presumption of public access[,]” as the relevant documents include information “that could cause competitive harm to [RAI] or the producer if released publicly,” Docket Item 79 at 5. More specifically, as discussed in greater detail below, RAI says that its PersonaSmart questions and analysis are proprietary and, furthermore, that those questions derive their value from not being known publicly. See generally id. at 7-10. Moreover, according to RAI, the disclosure of the two presentations and work proposal would harm non-party Fresenius by eliminating the

competitive advantage it gained from commissioning the relevant market research project.3 See generally id.; Docket Item 79-5. The Court turns first to the “PersonaSmart questions” and the presentation “contain[ing] the results of a PersonaSmart analysis,” Docket Item 59-8 at SMPA0000346.1-346.3 and Docket Item 65-2 at pages 4-121.

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Related

United States v. Amodeo
71 F.3d 1044 (Second Circuit, 1995)
Lugosch v. Pyramid Co. of Onondaga
435 F.3d 110 (Second Circuit, 2006)
GoSmile, Inc. v. Dr. Jonathan Levine, DMDPC
769 F. Supp. 2d 630 (S.D. New York, 2011)
United States v. Erie County
763 F.3d 235 (Second Circuit, 2014)
Brown v. Maxwell Dershowitz v. Giuffre
929 F.3d 41 (Second Circuit, 2019)
United States v. Amodeo
44 F.3d 141 (Second Circuit, 1995)

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