AAA Max 1 Limited v. The Boeing Company
2:23-cv-01356
W.D. Wash.Mar 1, 2024Background
- Plaintiffs (AAA Max 1-4 Limited and AAA B787 2-3 Limited) filed an action against The Boeing Company (Boeing) in the United States District Court for the Western District of Washington.
- Plaintiffs seek to file an Amended Complaint containing excerpts from and summaries of confidential contractual documents with Boeing regarding aircraft purchases and related services.
- Both parties stipulate that the information is commercially sensitive and subject to confidentiality agreements, potentially harming Boeing and its airline customers if disclosed.
- The parties request initial sealing of the Amended Complaint, followed by a review and potential redaction, to limit public access to commercially sensitive material.
- The court previously granted similar motions to seal or redact documents related to Boeing’s customer contracts in other cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sealing the Amended Complaint | No present objection; agrees it's appropriate to file under seal pending review. | Disclosure risks competitive/commercial harm to Boeing and its customers. | Court grants request to file under seal; orders further redaction review. |
| Public access to judicial records | Not directly addressed at this stage. | Strong presumption exists, but compelling reasons to seal apply here. | Sealing granted based on compelling reasons standard. |
| Sufficiency of confidentiality concerns | Not contesting sealing; leaves decision on permanent sealing for later. | Risks of unfair advantage to competitors and loss of customer negotiations leverage. | Initial sealing approved; permanent sealing/redactions to be considered after review. |
| Scope of sealing | Agrees to limit sealing to necessary portions after review. | Plans to propose redactions rather than full sealing if possible. | Court requires only limited redactions, consistent with least restrictive means. |
Key Cases Cited
- Center for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092 (9th Cir. 2016) (establishes strong presumption of access to court records but allows sealing for compelling reasons)
- Kamakana v. City & County of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (explains compelling reasons standard for sealing court records)
- Foltz v. State Farm Mut. Auto Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (discusses judicial records access presumption)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (identifies circumstances when sealing is appropriate to protect business interests)