United States of America v. Live Nation Entertainment, Inc.

CourtDistrict Court, S.D. New York
DecidedAugust 19, 2024
Docket1:24-cv-03973
StatusUnknown

This text of United States of America v. Live Nation Entertainment, Inc. (United States of America v. Live Nation Entertainment, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States of America v. Live Nation Entertainment, Inc., (S.D.N.Y. 2024).

Opinion

The Honorable Arun Subramanian August 19, 2024 Daniel Patrick Moynihan U.S. Courthouse 500 Pearl St., Courtroom 15A New York, NY 10007 Re: United States et al. v. Live Nation Entertainment, Inc., et al., No. 1:24-cv-3973-AS Dear Judge Subramanian: Plaintiffs seek the Court’s leave to file under seal an Amended Complaint and to file a redacted version of the same on the public docket for the reasons stated below. Contemporaneous with the filing of this letter-motion, and in accordance with Paragraph 11(c)(iii) of the Court’s Individual Practices and Paragraph 9 of the Protective Order, ECF No. 213, Plaintiffs are (1) publicly filing on ECF a copy of the Amended Complaint with proposed redactions and (2) filing under seal on ECF an unredacted copy of the Amended Complaint with proposed redactions highlighted. Plaintiffs Seek Provisional Redaction of the Amended Complaint Solely to Comply with the Protective Order and the Court’s Individual Practices Plaintiffs request provisional redaction of the Amended Complaint only because it contains information that Defendants have designated as Confidential or Highly Confidential and have requested to be redacted. The Protective Order and Your Honor’s Individual Practices govern the procedures for filing such material on the Court’s docket. Those procedures are three-fold. First, if a person produces material designated Confidential or Highly Confidential, any other person that intends in good faith to make a filing on the Court’s docket containing such material may request that the producing party provide a version of the material “with the Highly Confidential or Confidential information redacted.” Protective Order ¶ 4. Such redactions “must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents.” Individual Practices ¶ 11(B). Second, the filing party “should meet and confer with any opposing party . . . in advance to narrow the scope of the request” for redaction or sealing. Individual Practices ¶ 11(C)(i); accord Protective Order ¶ 9 (“The parties will use their best efforts to minimize such sealing.”). If, following that meet and confer, the opposing party or third party “has requested” that a document be filed “under seal or in redacted form,” then “the filing party shall notify the opposing party or third party that it must file, within three business days [of filing], a letter explaining the need to seal or redact the document.” Individual Practices ¶ 11(C)(i). Third, the filing party must file under seal “all portions of pleadings, motions, or other papers . . . that disclose such Highly Confidential or Confidential” material, and the filing “shall be . . . kept under seal until further order of the Court.” Protective Order ¶ 9. To do so, the filing party must “file a letter-motion seeking leave to file a document in redacted form,” which “shall be filed in public view” and “should explain the reasons for seeking to file the document in redacted form.” Individual Practices ¶ 11(C)(iii). highlighted.” Id. Plaintiffs followed these procedures as to both non-parties and Defendants. After conferrals, no non-party requested redaction of any information in the Amended Complaint. As to Defendants, Plaintiffs first identified the specific portions of documents designated Confidential or Highly Confidential that are the basis for the redacted portions of the Amended Complaint and asked Defendants to propose redactions to those documents. Plaintiffs sent Defendants such requests on June 13, June 26, and July 25. Defendants responded to the first two requests on July 2, 2024, and they responded to the third request on August 14, fourteen business days after it was made and three business days before the Amended Complaint was due to be filed. In an effort to eliminate, or at least narrow, the need for redactions, Plaintiffs requested on August 15 to meet and confer with Defendants about Defendants’ basis for the proposed redactions that are the subject of the present letter-motion. Defendants, however, did not make themselves available for such a conferral. Defendants Must Show “Extraordinary Circumstances” to Justify Any Continuing Redaction of the Amended Complaint Plaintiffs request provisional redaction of certain information from the Amended Complaint solely because Defendants requested such redaction. Plaintiffs do not believe, however, that the information at issue should remain sealed because it is not confidential or sensitive enough to overcome the “presumption of public access” to “judicial documents.” Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132, 141 (2d Cir. 2016). That presumption is “firmly rooted in our nation’s history,” deriving from both the common law and the First Amendment. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119–20 (2d Cir. 2006). The presumption of public access applies with special force to a complaint because, among other things, (1) “[c]omplaints have historically been publicly accessible by default, even when they contain arguably sensitive information,” (2) “public access to the complaint and other pleadings has a ‘significant positive role’ in the functioning of the judicial process,” and (3) complaints “are highly relevant to the exercise of Article III judicial power” and “among the most likely [records] to affect judicial proceedings.” Bernstein, 814 F.3d at 141–42 (citation omitted). For core judicial documents like a complaint, the presumption of public access “is at its zenith, and thus can be overcome only be extraordinary circumstances.” Id. (citation omitted). “The burden of demonstrating that a document submitted to a court should be sealed rests on the party seeking such action,” DiRussa v. Dean Witter Reynolds Inc., 121 F.3d 818, 826 (2d Cir. 1997), and sealing “should not be done without a compelling reason,” City of Hartford v. Chase, 942 F.2d 130, 135 (2d Cir. 1991). Therefore, Defendants, as the only parties advocating continuing redaction of the Amended Complaint, have the burden to establish “a compelling reason” and “extraordinary circumstances” to maintain redactions. Defendants’ burden extends to each specific piece of information. See Brown v. Maxwell, 929 F.3d 41, 48–51 (2d Cir. 2019) (court must conduct “individualized review” and make “specific, on-the-record findings that sealing is necessary to preserve higher values”). Although Defendants have not yet explained their basis for their redaction Defendants can carry their burden of showing “extraordinary circumstances,” Bernstein, 814 F.3d at 142, or establishing that all of the redactions at issue are otherwise “consistent with the presumption in favor of public access to judicial documents.” Individual Practices § 11(B). Although Plaintiffs request a fuller opportunity to respond to any letter-motion to seal filed by Defendants, the redactions at issue do not appear to present a sufficient “risk of competitive disadvantage” to overcome the strong presumption of public access to complaints. See Wenger S.A. v. Olivet Int'l Inc., 2024 WL 3581796, at *2 (S.D.N.Y. June 25, 2024) (Subramanian, J.) (denying proposed redactions in a summary judgment opinion). Much, if not all, the information at issue appears to be sufficiently aggregated, non-specific, historical or otherwise competitively non-actionable, such that public disclosure would be unlikely to cause Defendants harm.

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Related

Lugosch v. Pyramid Co. of Onondaga
435 F.3d 110 (Second Circuit, 2006)
Brown v. Maxwell Dershowitz v. Giuffre
929 F.3d 41 (Second Circuit, 2019)
DiRussa v. Dean Witter Reynolds Inc.
121 F.3d 818 (Second Circuit, 1997)
City of Hartford v. Chase
942 F.2d 130 (Second Circuit, 1991)

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Bluebook (online)
United States of America v. Live Nation Entertainment, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-live-nation-entertainment-inc-nysd-2024.