U.S. Bank National Association v. North American Title Insurance Company

District Court, D. Nevada·Decided June 2, 2023·No. 2:19-cv-00424·Unknown

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 * * *

4 U.S. BANK NATIONAL ASSOCIATION, Case No. 2:19-cv-00424-JAD-EJY

5 Plaintiff,

6 v. ORDER

7 NORTH AMERICAN TITLE INSURANCE COMPANY, 8 Defendant. 9 10 Pending before the Court is the Motion to Seal in which Defendant contends two exhibits 11 and a portion of a deposition transcript must be sealed because these exhibits reveal Defendant’s 12 trade secrets. ECF No. 43. Plaintiff opposes Defendant’s Motion. Plaintiff contends the exhibits 13 Defendant seeks to seal “are simply a regurgitation of industry custom and trade usage that has 14 existed for decades and is widely available from public resources, including … [Defendant’s] own 15 website.” ECF No. 60. In its Reply, Defendant points to a prior order of the Court sealing the 16 identical documents in another case and says that while a recitation and analysis of Nevada Supreme 17 Court case law may not be unique, “its instructions to its agents as to how to move forward” warrants 18 sealing because disclosure may give an unfair advantage to Defendant’s competitors. ECF No. 63. 19 I. Discussion. 20 A. Arguments Presented By The Parties. 21 In its Motion, Defendant describes Exhibits O and P as underwriting bulletins “reflect[ing] 22 the mental thoughts and impressions of underwriting counsel … constitute[ing] … [Defendant’s] 23 guidance to its title agents[] regarding the risks … [Defendant] is (and is not) willing to undertake.” 24 ECF No. 43 at 3. Defendant further says that because this information is a trade secret, Defendant 25 “takes every reasonable precaution to prevent the dissemination of these underwriting bulletins 26 beyond the circle of people who need to know their contents.” Id. Defendant contends it gives 27 “strict instructions” to title agents not to “release the underwriting bulletins to anyone else.” Id. 1 Defendant’s Motion relies on the Declaration of David Schreiber (the “Schreiber Dec.”) to 2 support the above argument. Mr. Schreiber is “senior claims counsel” for Defendant and says the 3 “underwriting bulletins set forth … [Defendant’s] underwriting standards” for its title agents, the 4 bulletins represent risks Defendant will and will not undertake, which is a trade secret and, as such, 5 the bulletins are disseminated to Defendant’s title agents who are instructed not to provide these 6 bulletins to anyone else. ECF No. 43-1 ¶¶ 1, 7. 7 In response, Plaintiff argues Defendant “never asserts the[] [b]ulletins actually disclose an 8 internally created method to address a risk” Defendant is or is not willing to take. ECF No. 60 at 5. 9 Plaintiff says Defendant concede it discloses the bulletins to independent agents who are third parties 10 not required to maintain confidentiality. Id. citing Bayview Loan Servicing, LLC v. North American 11 Title, 2:19-cv-01151-JAD-EJY (“Bayview”), ECF No. 137 at 5:15-6:10.1 Discussing the Schreiber 12 Dec., Plaintiff argues Mr. Schreiber fails to demonstrate personal knowledge of the facts he asserts 13 as he is claims counsel, not underwriting counsel, the Declaration is, at best, imprecise because 14 Defendant’s agents are actually independent agents that Defendant “does not control,” Defendant 15 therefore discloses trade secrets to third parties, and Defendant does not provide any authority or 16 support for the contention that these independent agents must keep the information confidential. 17 ECF No. 60 at 6. Plaintiff supports this argument by citing to the November 3, 2020 deposition of 18 Mr. Pelt, in which the following exchange occurred:

19 Q: So what, if anything does … [Defendant] do to require its agents to maintain the confidentiality of these two bulletins? 20 A: We really haven’t had to give express instructions. Again, custom and 21 practice in the industry, it’s just understood that this information is to be kept to various underwriters. 22 23 ECF No. 60-1 at 4. Plaintiff further cites Mr. Pelt’s testimony showing that “on a case-by-case basis” 24 he makes the decision, depending on who is asking and for what purpose, to disclose the bulletins to 25

26 1 Despite Plaintiff’s representation, the Court notes this citation further cites Bayview, at ECF No. 37-1 (the Declaration of Kent Pelt, Regional Underwriting Counsel for Defendant) ¶ 4, in which Mr. Pelt states Defendant 27 “considers these underwriting bulletins to be confidential and trade secrets. For that reason, … [Defendant] only disseminates these underwriting bulletins to its independent and affiliated policy issuing agents. Otherwise, these 1 non-agent third parties. Id. Plaintiff submits the totality of the record demonstrates Defendant does 2 not maintain strict confidentiality of the bulletins at issue. ECF No. 60 at 7.2 3 Plaintiff also says the information in the bulletins is published on Defendant’s website. Id. 4 at 8. Plaintiff states the bulletins are “materially identical to widely publicized and publicly available 5 trade usage materials” citing case law, contents of a publication by the former chair of the ALTA 6 forms committee, and publications by other title insurance companies. Id. at 9-14. 7 In Reply, Defendant cites the Court’s Order issued approximately three years ago in which 8 it found the same bulletins at issue here were properly sealed. ECF No. 63 at 4-5. Further, Defendant 9 accurately argues that Plaintiff’s reliance on an order issued by U.S. District Judge Andrew P. 10 Gordon in an unrelated case is misplaced. Id. at 5. In Deutsche Bank National Trust Company v. 11 Westcor Land Title, Case No. 2:20-cv-01706-APG-VCF, the plaintiff moved to seal a bulletin the 12 defendant title company marked as confidential. The court entered a minute order indicating its 13 intent to deny the motion because there was no need to seal the exhibit at issue. See id. at ECF No. 14 69. The court provided Defendant an opportunity to respond to the minute order, explaining if 15 defendant failed to respond, the court would deny the motion to seal. Id. The defendant title 16 company failed to respond to the court’s order and the document at issue was unsealed. Id. The 17 order did not discuss the content of the bulletin, whether the bulletin contained trade secrets or why 18 the court found no basis to seal the document. Id. 19 Defendant further argues one of the two bulletins at issue does not only “contain a discussion 20 of the endorsements—it also contains guidance specifically directed to its title agents in light of its 21 analysis of the endorsements ….” ECF No. 63 at 6. Defendant says it does not matter whether other 22 title insurers “provide similar analysis” that is publicly available because Defendant’s provide 23 “analysis and guidance to its agents … in its confidentially [] held bulletins.” Id. at 7. Defendant 24 argues the three sentences Plaintiff cites from its webpage is not equivalent to the five pages in the 25 bulletin that is “not on its website but rather was sent directly to … [Defendant’s] agents and 26 thereafter … [is] password [] protected.” Id.

27 2 Plaintiff does not take issue with Mr. Pelt’s expertise. However, Plaintiff contends the specific deposition 1 Defendant contends the bulletins “indicate” they are “for use by” its agents and “no other 2 party is authorized to rely on” the contents. Id. at 8. Citing case law, Defendant argues the non-use 3 of a confidentiality agreement, while an important factor, is not determinative of whether it took 4 reasonable steps to maintain the confidentiality of the documents at issue. Id. (citations omitted). 5 Finally, Defendant argues that any public interest in the bulletins is outweighed by the harm 6 Defendant will suffer if the bulletins (and testimony regarding the bulletins) are not sealed. Id. 7 B. Summary of the Law.

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U.S. Bank National Association v. North American Title Insurance Company, (D. Nev. 2023).

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