J&R Passmore, LLC v. Rice Drilling D, LLC, 2:18-cv-01587

Plaintiffs moved for leave to file under seal eleven spreadsheet exhibits submitted with their reply in support of class certification, which contain well-level revenue and expense data.
Parties initially had not all conferred; after conferment they declassified several exhibits but retained the eleven contested spreadsheets as confidential.
The Court conducted an in camera review and found the spreadsheets contain sensitive financial data unlikely known outside the businesses and protected by contract.
The Court applied the Sixth Circuit sealing framework (Shane Group) requiring a compelling interest, a balancing of public interest, and narrow tailoring.
The Court found the spreadsheets qualify as trade secrets, no countervailing public interest justified disclosure, and that full sealing was necessary because line-by-line redaction was not feasible.
The parties agreed to declassify certain other exhibits with redactions of personal employee contact information; the Court approved those redactions and ordered filing consistent with the opinion within seven days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the spreadsheets may be sealed as trade secrets	Spreadsheets contain sensitive financial/revenue and expense data that constitute trade secrets and should be sealed	Parties agreed the information is confidential; no public-disclosure objection recorded	Court: Seal granted — financial data qualifies as trade secret satisfying compelling-interest prong
Whether public interest outweighs sealing	Little to no public benefit from disclosure; case not implicating public health/safety	Public access presumption exists, but parties emphasized confidentiality	Court: No countervailing public interest; sealing justified
Whether sealing request is narrowly tailored (redaction vs full seal)	Redaction infeasible because each line contains confidential data; full sealing necessary	Parties agreed some documents could be redacted; for these spreadsheets redaction impracticable	Court: Full sealing of the eleven spreadsheets is narrowly tailored; approved limited redactions for other documents
Whether redaction of employee contact info is appropriate	Redacting personal employee contact information protects privacy of nonparties	Parties agreed to redact such personal information	Court: Approved redactions as narrowly tailored and protective of third-party privacy

Shane Grp., Inc. v. Blue Cross Blue Shield of Michigan, 825 F.3d 299 (6th Cir. 2016) (establishes strong presumption of public access to court records and sealing framework)
Brown & Williamson Tobacco Corp. v. F.T.C., 710 F.2d 1165 (6th Cir. 1983) (recognizes presumption of openness and limited exceptions)
Baxter Int'l, Inc. v. Abbott Labs., 297 F.3d 544 (7th Cir. 2002) (distinguishes discovery materials from court record and marks when public access attaches)
Handel's Enters., Inc. v. Schulenberg, [citation="765 F. App'x 117"] (6th Cir. 2019) (defines trade secret elements applied to financial information)
Kondash v. Kia Motors Am., Inc., [citation="767 F. App'x 635"] (6th Cir. 2019) (explains that trade secret finding generally satisfies compelling-interest prong and discusses balancing/narrow-tailoring)