Carbon Autonomous Robotic Systems Inc. v. Laudando & Assoc.
2:24-cv-03012
| E.D. Cal. | Jun 13, 2025Background
- Both plaintiff Carbon Autonomous Robotic Systems Inc. and defendant Laudando & Associates LLC filed renewed motions to seal and redact certain documents related to plaintiff’s motion for preliminary injunction in a patent infringement suit.
- The court had previously denied initial sealing requests for failing to articulate compelling reasons, as required by law.
- The contested documents include confidential business, financial, technical, and customer information for both parties.
- Both parties agreed not to oppose each other's renewed sealing requests after meeting and conferring.
- The court noted that redacted versions of documents had already been filed on the public record, prior to court authorization.
- The procedural posture centers on the production and public accessibility of documents and information central to the preliminary injunction motion, which is closely linked to key merits of the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether confidential documents related to the preliminary injunction should be sealed/redacted under the “compelling reasons” standard | Disclosure would cause competitive harm; requests are narrowly tailored to confidential info | Seeks to maintain redactions of financial, technical, and business info; requests also narrowly tailored | Both parties met the compelling reasons standard; sealing and redactions granted |
| Whether the preliminary injunction motion is subject to “compelling reasons” standard due to its relation to the merits | The motion is closely tied to the merits and relief sought; so sealing must meet strict scrutiny | No direct argument; does not contest application of standard | Court finds the motion is more than tangential to merits; “compelling reasons” standard controls |
| Sufficiency and scope of redactions (i.e., are requests narrowly tailored?) | Filed redacted versions; only sealed specific confidential info | Filed redacted versions; limited to necessary confidential data | Both parties’ requests found to be narrowly tailored and properly limited |
| Procedural compliance after prior denial (proper justification for renewed requests) | Provided detailed business and competitive harm justification; addressed court’s prior concerns | Justification thinner, but not opposed by plaintiff and tied to confidential content present | Both parties cured defects; court grants renewed motions to seal and redact |
Key Cases Cited
- San Jose Mercury News, Inc. v. U.S. Dist. Court, 187 F.3d 1096 (9th Cir. 1999) (presumption of public access to court records)
- Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (distinction between compelling reasons and good cause standards for sealing)
- Pintos v. Pac. Creditors Ass'n, 605 F.3d 665 (9th Cir. 2010) (differentiating standards for dispositive and non-dispositive motions)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (general right to access judicial records and exceptions for misuse or trade secrets)
- Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092 (9th Cir. 2016) (compelling reasons test applies when motion is more than tangentially related to the merits)