Kimera Labs Inc v. Jayashankar
3:21-cv-02137
| S.D. Cal. | Jun 23, 2025Background
- Kimera Labs, Inc., an FDA-registered tissue processing company, sued several former employees and Exocel Bio Inc. for alleged trade secret misappropriation and unjust enrichment after they allegedly took confidential information to create a competing business.
- The lawsuit includes claims under the Federal Trade Secrets Act and Florida unfair enrichment law.
- Both sides filed Daubert motions contesting the admissibility of expert testimony, and Defendants moved for summary judgment.
- Parties filed motions to seal portions of their filings, arguing they contain confidential business information and trade secrets.
- The parties largely did not oppose each other's motions to seal specific materials, providing public redacted versions and sealed, unredacted versions to the court.
- The court considered whether the sealing requests met the legal standard for restricting public access to judicial records.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether confidential information or trade secrets in Daubert and summary judgment filings should be sealed | Disclosure risks trade secrets and confidential business processes | Some information is not protectable as trade secrets, so sealing is unnecessary | Sealing proper; compelling reasons standard met |
| Applicable standard for sealing (compelling reason or good cause) | Compelling reasons exist to seal sensitive information | Filing is not meritorious enough to require strict sealing | Compelling reasons standard applies |
| Whether public versions are sufficient with limited redactions | Minimal redactions preserve confidentiality without over-sealing | Redactions do not address underlying claim of non-trade secret status | Minimal redactions acceptable; sealing otherwise appropriate |
| Timing of addressing trade secret status re: sealing | Sealing should be determined now to avoid unnecessary disclosure | Determining trade secret status should take precedence over sealing decision | Sealing is decided independently of trade secret merits |
Key Cases Cited
- Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (sets "compelling reasons" standard for sealing court records)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (discusses presumption of public access and exceptions for trade secrets)
- Oliner v. Kontrabecki, 745 F.3d 1024 (9th Cir. 2014) (importance of public access to judicial records)
- United States v. Bus. of Custer Battlefield Museum & Store, 658 F.3d 1188 (9th Cir. 2011) (articulates standards for sealing depending on relevance)
- Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092 (9th Cir. 2016) (distinguishes between "compelling reason" and "good cause" standards for sealing)