Tesla, Inc. v. Proception, Inc., et al.

Opinion

1 2 3 6 7 TESLA, INC., Case No. 25-cv-04963-SVK

8 Plaintiff, ORDER GRANTING IN PART THE 9 v. PARTIES’ MOTIONS TO SEAL RE PRELIMINARY INJUNCTION 10 PROCEPTION, INC., et al., BRIEFING AND SUBMISSIONS 11 Defendants. Re: Dkt. No. 17, 44, 65, 70, 71, 90, 91

12 Before the Court are various administrative motions to seal filed by the Parties in 13 connection with Plaintiff’s Motion for Preliminary Injunction (Dkt. 14) and subsequent briefing.1 14 Dkts. 17, 44, 65, 70, 71, 90, 91. Pursuant to Civil L.R. 79-5(f), where required, Tesla has filed 15 statements in support of the requested sealing. See Dkts. 81, 94. The sealing motions have been 16 unopposed, except for Defendants’ partial opposition of Tesla’s sealing request at Dkt 81. See Dkt. 17 83. Thereafter, Tesla filed an amended statement in support of sealing, (see Dkt. 86), proposing 18 narrowed redactions which Defendants have not opposed. Having considered the Parties’ 19 submissions, the relevant law and the record in this action, the motions are GRANTED IN PART. 20 Courts recognize a “general right to inspect and copy public records and documents, 21 including judicial records and documents.” Kamakana v. City & Cnty. Of Honolulu, 447 F.3d 22 1172, 1178 (9th Cir. 2006) (quoting Nixon v. Warner Commc’ns., Inc., 435 U.S. 589, 597 & n.7 23 (1978)). The standard for overcoming the presumption of public access to court records depends 24 on the purpose for which the records are filed with the court. A party seeking to seal court records 25 relating to motions that are “more than tangentially related to the underlying cause of action” must 26 demonstrate “compelling reasons” that support secrecy. Ctr. For Auto Safety v. Chrysler Grp., 27 1 809 F.3d 1092, 1099 (9th Cir. 2016). For records attached to motions that are “not related, or only 2 tangentially related, to the merits of the case,” such as “a discovery motion unrelated to the merits 3 of the case,” the lower “good cause” standard applies. Id.; see also Kamakana, 447 F.3d at 1179. 4 The requests at issue relate information submitted in support of Tesla’s Motion for Preliminary 5 Injunction, which relates to the merits of Tesla’s misappropriation claims. Accordingly, the 6 “compelling reasons” standard applies. 7 The Court appreciates the Parties’ care in proposing narrow redactions, and Tesla’s 8 willingness to further narrow redactions upon objection by Defendants. Upon the Court’s review, 9 the primary material that the Parties continue to request remain under seal are specifics such as file 10 names, file paths, employee names (of employees who have not submitted declarations in this 11 case), team structure information and third-party vendor details. See, generally, Table below. 12 Such material is of limited public value and its disclosure would cause harm both to Tesla, in the 13 form of posing security vulnerabilities for Tesla’s Optimus network, and specific employees of the 14 Parties, in the form of disclosing personally identifiable information. Moreover, the Court does 15 not refer to such sealed information in its accompanying Order, such that it is of limited public 16 value. Accordingly, the Court finds compelling reasons to maintain such information under seal. 17 Additionally, in select cases Tesla has sought to seal sensitive project details related to its 18 Optimus technology. For the most part, the Court agrees that the disclosure of such non-public 19 and specific information would endanger Tesla’s Optimus-related trade secrets and inflict 20 competitive harm on Tesla. Moreover, the Court does not refer to any such highly sensitive 21 information in its accompanying Order. Accordingly, the Court finds compelling reasons to 22 maintain such information under seal, except as noted below. 23 In summary, the Court GRANTS IN PART the Parties’ motions to seal as follows:

24 Document Portions to Be Sealed Court Ruling First Declaration of Highlighted portions at ECF pages: For the reasons 25 Prem Pinto in Support 3:12-13 (filename) explained above, of Preliminary 3:20 (filename) GRANTED. 26 Injunction 3:26-27 (filename) 4:5 (filename) 27 [Dkt. 17-4] 4:13 (filename) 4:28-5:1 (filenames) Document Portions to Be Sealed Court Ruling 1 6:3–4 (filenames) 2 The Access Log (both Dkt. 14-34 shall be the corrected and All file paths contained in the maintained under seal, 3 original versions), i.e. ObjectId and SiteUrl columns; as it is superseded by Tabs A-K of Exhibit A Dkt. 44-4 and was not 4 to the Declaration of Select file names highlighted in the considered by the Jeff Liang in Support of SourceFileName column. Court. Sealing of Dkt. 5 Preliminary Injunction 44-4 is GRANTED for the reasons 6 [Dkt. 14-34 (original)] explained above. [Dkt. 44-4 (corrected)] 7 Tesla’s Supplemental Highlighted portions at ECF pages: For the reasons 8 Brief in Support of 4:17 (filename excerpt) explained above, Preliminary Injunction 5:9 (vendor name and filename) GRANTED. 9 [Dkt 65-4] 10 Exhibit A to Highlighted portions at ECF pages: For the reasons 11 Declaration of David 2 (filenames within file paths) explained above, Lee in Support of 3 (filenames within file paths) GRANTED. 12 Supplemental Brief in Support of Preliminary 13 Injunction

14 [Dkt. 65-14] Exhibit B to Declaration Highlighted portions at transcript pages: GRANTED IN 15 of Angelique Kaounis 48:9, 11, 14, 16 (employee names) PART for the reasons in Support of 51:20-24 (team structure information) explained above, 16 Supplemental Brief in 54:13, 25 (reference to team name) except for 54:13, Support of Preliminary 74:14, 19 (employee names) 54:25, which is 17 Injunction 134:5-6 (Optimus project detail) GRANTED as 217:1, 22 (Optimus project detail) unopposed and due to 18 [Dkt. 65-5] 217:25 (vendor name) its limited public value 222:25 (filename excerpt) and impact on the 19 226:14 (Optimus project detail name Court’s accompanying and codename) Order. 20 226:25 (Optimus project detail) 230:17 (Optimus project detail name) DENIED as to 21 240:9-10, 23 (Optimus project detail) 204:24-205:5, 217:8 250:5, 16 (employee name) and 252:16-18 as 22 being information of a sufficiently high level 23 such that competitive or other harm is 24 unlikely to result. However, Tesla need 25 not re-file the transcript at this time. 26 Supplemental Highlighted portions at ECF pages: GRANTED IN Declaration of Prem 2:24 (file description and codename) PART for the reasons 27 Pinto in Support of 3:7 (vendor name and filename) explained above. Preliminary Injunction 4:1 (filename description) Document Portions to Be Sealed Court Ruling 1 [Dkt. 65-6] 12 as being information of a 2 sufficiently high level such that competitive 3 or other harm is unlikely to result, and 4 as being highly relevant to the Court’s 5 opinion and thus of potential interest to the 6 public. Exhibits A-G to the Entire documents GRANTED as entire 7 Supplemental documents allegedly Declaration of Prem containing Optimus- 8 Pinto in Support of hands trade secrets and Preliminary Injunction whose disclosure, 9 other than at a very [Dkts. 65-7–65-13] high level, would 10 endanger the trade secrets therein and 11 inflict competitive harm to Tesla. 12 Declaration of Zhongjie Highlighted portions at paragraphs: For the reasons “Jay” Li in Opposition 46a.-f (Proception employee names explained above, 13 to Tesla’s Motion for and links to their LinkedIn pages) Defendants motion to Preliminary Injunction seal is GRANTED. 14 Additional portions at ECF pages: [Dkt. 70-3] 3:4-5 (Tesla employee name) Tesla’s motion to seal 15 3:5-6 (Tesla employee name) is GRANTED IN 3:6 (Tesla employee name) PART AND DENIED 16 3:7-8 (team structure information) IN PART. Certain 3:9-12 (team structure information) recitations of team 17 3:10 (Tesla employee name) structure and Optimus 3:15 (Tesla employee name) project information are 18 3:20 (Tesla employee name) at a sufficiently high 3:21-22 (team structure information) level such that 19 3:22-24 (employee & intern names) competitive or other 3:24 (Tesla employee names) harm is unlikely to 20 3:27 (team structure information) result and, moreover, 4:1 (team structure information) is highly relevant to 21 4:2 (sensitive Optimus project detail) the Court’s opinion 4:4 (sensitive Tesla project details) and thus of potential 22 4:11 (Tesla employee name) interest to the public. 4:12 (Tesla employee name) 23 4:13 (team structure information) 4:16 (Tesla employee names) 24 4:19 (Tesla employee name) 4:22 (Tesla employee names) 25 4:22-23 (team structure information) 4:23 (Tesla employee name) 26 4:26 (Tesla employee name) 5:1 (Tesla employee names) 27 5:9 (Tesla employee name) Document Portions to Be Sealed Court Ruling 1 5:18 (Tesla employee name) 5:19-21 (team structure information) 2 6:1-2 (team structure information) 6:5 (sensitive Optimus project details) 3 6:9-10 (Tesla employee names) 6:13 (Tesla employee names) 4 6:15 (Tesla employee names) 8:20 (Tesla employee name) 5 8:21 (Tesla employee & vendor name) 8:22 (vendor details) 6 8:23 (vendor details) 8:23 (Tesla employee name) 7 8:27 (Tesla employee name) 8:28 (Tesla intern name) 8 9:1 (Tesla intern name) 9:2 (Tesla intern name) 9 9:7-8 (confidential file title) 9:15 (Tesla employee name) 10 9:18 (Tesla intern name) 9:23 (vendor details) 11 10:19 (vendor details) 10:20 (vendor details) 12 12:17 (vendor details) 12:18 (vendor details) 13 Defendant’s Opposition Portions at PDF pages: For the reasons to Tesla’s Motion for explained above, 14 Preliminary Injunction ii:7 (vendor details) GRANTED. ii:18 (vendor details) 15 [Dkt. 71-2] 3:19 (name of Tesla employee) 3:24-26 (names of Tesla employees) 16 3:26 (names of Tesla employees) 6:12 (vendor details) 17 6:16 (title of sensitive Optimus document) 6:16 (vendor details) 18 6:17 (vendor details) 6:19 (vendor details) 19 6:20 (vendor details) 6:20 (name of Tesla employee) 20 6:21 (vendor details) 7:4 (name of Tesla employee) 21 7:10 (vendor details) 7:11 (vendor details) 22 7:14 (vendor details) 9:4 (title of sensitive Optimus document) 23 10:15 (vendor details) 11:25 (Tesla intern name) 24 16:5 (vendor details) 18:16 (vendor details) 25 19:13 (Tesla intern name) 20:25 (vendor details) 26 21:2-3 (vendor details) 21:6 (vendor details) 27 21:8 (vendor details) Document Portions to Be Sealed Court Ruling 1 21:15 (vendor details) 21:20 (vendor details) 2 21:24 (vendor details) 22:15 (vendor details) 3 22:16 (vendor details) 22:27 (vendor details) 4 23:11 (name of Tesla employee) 23:11 (vendor details) 5 23:15 (vendor details) 23:16 (vendor details) 6 24:3 (vendor details) 25:15 (vendor details) 7 25:18 (vendor details) 26:1 (vendor details) 8 27:22 (vendor details) 29:14 (vendor details) 9 29:16 (vendor details) 33:22 (vendor details) 10 Declaration of Jaideep Portions at PDF pages: For the reasons 11 Venkatesan in explained above, Opposition to Tesla’s 3:14 (confidential Tesla file name) GRANTED. 12 Motion for Preliminary 3:15-17 (sensitive Tesla vendor Injunction details) 13 3:19-20 (sensitive Tesla vendor [71-4] details) 14 Exhibit B to Venkatesan Entire document The Court did not Declaration consider or cite these 15 transcript pages in its [Dkt. 71-5] accompanying Order, 16 and thus may maintain this discovery 17 document under seal as having little, if any, 18 public value at this time. 19 Exhibit C to Venkatesan Redactions as proposed by Tesla in its GRANTED for the Declaration amended statement, see Dkt. 85-1. reasons explained 20 above, including [Dkt. 71-6] because the narrowed 21 redactions are unopposed by 22 Defendants and because the details 23 sought to be redacted are at a much more 24 granular level than the corresponding high- 25 level statements in, e.g., the Opposition. 26 Exhibit D to Entire document GRANTED as entire Venkatesan Declaration document allegedly 27 containing Optimus- Document Portions to Be Sealed Court Ruling 1 other than at a very high level, would 2 endanger the trade secrets therein and 3 inflict competitive harm to Tesla. 4 Exhibit E to Venkatesan Entire document (LinkedIn Profile) For the reasons Declaration explained above, 5 GRANTED. [Dkt. 71-8] 6 Exhibit F to Venkatesan Redactions as proposed by Tesla in its GRANTED IN Declaration amended statement, see Dkt. 85-2, PART for the reasons 7 except not the following: explained above, [Dkt. 71-9] including because the 8 “actuator w foot,” narrowed redactions “Gen w [h]and,” are unopposed by 9 “foot w sensor,” Defendants and “gen 4,” because the details 10 “gen” sought to be redacted “gen 1” are at a more granular 11 “gen4” level than the “4 [h]ands Gen4” corresponding high- 12 level statements in, e.g., the Opposition. 13 However, sealing of a 14 few of the terms herein are DENIED as 15 follows, because they are either of a 16 sufficiently high level, have been made 17 otherwise public, or else are highly relevant 18 to the Court’s accompanying order 19 and thus of significant public interest. 20 Exhibit G to Redactions as proposed by Tesla in its For the reasons Venkatesan Declaration amended statement, see Dkt. 85-3. explained above, 21 GRANTED. [Dkt. 71-10] 22 Exhibits K to Entire document GRANTED as entire Venkatesan Declaration document allegedly 23 containing Optimus- [Dkt. 71-11] hands trade secrets and 24 whose disclosure, other than at a very 25 high level, would endanger the trade 26 secrets therein and inflict competitive 27 harm to Tesla. Document Portions to Be Sealed Court Ruling 1 containing Optimus- [Dkt. 71-12] hands trade secrets and 2 whose disclosure, other than at a very 3 high level, would endanger the trade 4 secrets therein and inflict competitive 5 harm to Tesla. Exhibit M to Entire document (LinkedIn Profile) For the reasons 6 Venkatesan Declaration explained above, GRANTED. 7 [Dkt. 71-13] Exhibits N to Entire document GRANTED as entire 8 Venkatesan Declaration document allegedly containing Optimus- 9 [Dkt. 71-14] hands trade secrets and whose disclosure, 10 other than at a very high level, would 11 endanger the trade secrets therein and 12 inflict competitive harm to Tesla. 13 Exhibit O to Entire document The Court did not Venkatesan Declaration consider or cite these 14 transcript pages in its [Dkt. 71-15] accompanying Order, 15 and thus may maintain this discovery 16 document under seal as having little, if any, 17 public value at this time. 18 Exhibit P to the DENIED. This Venkatesan Declaration document is a 19 published research [Dkt. 71-16] article and, 20 accordingly, is not confidential and may 21 not be maintained under seal. Moreover, 22 in its supporting statement, Tesla does 23 not seek to maintain this document under 24 seal. Exhibit Q to the DENIED. This 25 Venkatesan Declaration document is a published research 26 [Dkt. 71-17] article and, accordingly, is not 27 confidential and may Document Portions to Be Sealed Court Ruling 1 not seek to maintain this document under 2 seal. Declaration of Lucas Portions at ECF pages: For the reasons 3 Woodland in explained above, Opposition to Tesla’s 4:21-22 (filename) GRANTED. 4 Motion for Preliminary 4:22 (vendor name) Injunction 4:23 (vendor name) 5 5:1 ((Tesla employee name) [Dkt. 71-18] 5:6, 5:7-8 (filename and employee 6 name visible in image) 5:15 (vendor name) 7 5:16-17 (file path and filename) 5:24 (vendor name) 8 6:4 (vendor name) 6:6 (vendor name) 9 6:16-17, 20-21 (filename and employee name visible in image) 10 7:14 (filename) 7:17-23 (filenames and file paths) 11 Exhibit A to the Redactions as proposed by Tesla in its For the reasons Woodland Declaration amended statement, see Dkt. 85-3. explained above, 12 GRANTED. [Dkt. 71-19] 13 Tesla’s Reply Brief in Highlighted portions at ECF pages: For the reasons Support of Preliminary explained above, 14 Injunction 10:6 (filename) GRANTED. 10:19 (filename) 15 [Dkt. 90-5] 10:24 (filename) 11:3 (filename) 16 11:8 (filename) 11:16 (filename) 17 11:20 (filenames) 11, fn. 5 (filenames) 18 12:3 (filename) 13:5 (filename) 19 13:7-8 (employee name) 13:11, 12, 13 (vendor name) 20 14:11-12 (vendor name)

21 Declaration of Terry Highlighted portions at paragraphs: For the reasons Ahearn in Support of explained above, 22 Preliminary Injunction 3 (employee name) GRANTED.

23 [Dkt. 90-6] Exhibit A to Ahearn Highlighted portions at ECF page 2 For the reasons 24 Declaration explained above, GRANTED. 25 [Dkt. 90-7] Third Declaration of Highlighted portions at ECF pages: For the reasons 26 Prem Pinto in Support explained above, of Preliminary 2:26 (filename) GRANTED. 27 Injunction 3:12 (filename) Court Ruling Declaration of Sean Entire document This document was McDermott in Support STRICKEN and, 2 of Preliminary accordingly, the Court Injunction did not consider it and 3 may maintain the Dkt. 90-8 document under seal. 4 Defendants’ Proposed Portions at PDF pages: For the reasons Sur-Reply in Opposition i:5 (name of Tesla employee) explained above, 5 to Tesla’s Motion for 1:8 (name of Tesla employee) GRANTED. Preliminary Injunction 1:9 (vendor name) 6 1:21 (Tesla employee name) [Dkt. 91-3] 1:23 (vendor name) 7 1:24 (Tesla employee name) 1:25 (Tesla employee name) 8 1:26 (Tesla employee name) 1:28 (employee name & vendor name) 9 2:1 (Tesla employee name) 2:1 (vendor name) 10 2:2 (vendor name) 2:3-4 (sensitive Tesla vendor 1 information) 2:8 (Tesla employee name) 12 2:9 (vendor name) 5 2:22-23 (filename) 13 2:25 (Tesla employee name) 2 n.1 (vendor name, vendor’s product name, and vendor website) 3:1-2 (filename 15 3:3 (Tesla employee name Defendants Objection to Portions at PDF pages: For the reasons 16 New Evidence and explained above, Argument in Tesla’s 3:23 (vendor name) GRANTED. 17 Reply ISO Motion for Preliminary Injunction a 18 Dkt. 91-2 19 The Clerk of the Court shall maintain Dkts. 17-4, 14-34, 44-4, 65-4, 65-5, 65-6, □□□□□□□□ 20 13, 65-14, 70-3, 71-2, 71-4-71-10, 71-11-17, 71-18, 71-19, 90-5—-90-9, 91-2 and 91-3 under seal. 21 Additionally, no later than December 1, 2025, in accordance with the Court’s order above, Tesla 22 shall file more narrowly redacted, public versions of Dkts. 65-6 (Supp. Decl. of Prem Pinto), 70-3 23 (Li Decl.), 71-2 (Defendants’ Opposition), 71-9 (Ex. F to the Venkatesan Decl.) and 71-18 24 (Woodland Decl.). The Clerk of Court shall unseal Dkts. 71-16 and 71-17 in their entirety. 26 Dated: November 14, 2025 27 Sum verKul 28 SUSAN VAN KEULEN United States Magistrate Judge