Laatz v. Zazzle, Inc.
5:22-cv-04844
| N.D. Cal. | Aug 28, 2025Background
- Defendants Zazzle, Inc. and Mohamed Alkhatib moved to file under seal materials attached to their Daubert motion to exclude Plaintiff Nicky Laatz’s expert. The sealing motion addressed multiple redactions and exhibits.
- Plaintiff opposed most sealing requests and expressly stated she did not request sealing for certain documents designated confidential by her.
- The court applied the higher “compelling reasons” standard because the sealing requests relate to a dispositive (Daubert) motion.
- Defendants sought to seal: technical details of Zazzle’s Design Tool and servers, and business metrics (numbers of designers, designs, products, users) and financial figures (sales, revenues, expenses, damages calculations).
- The court denied sealing for materials that Plaintiff did not seek sealed and for materials already publicly disclosed on the docket (e.g., certain redactions on page 12 and Exhibits G, I, J; Exhibits R1/R2 and a referenced email).
- The court granted narrowly tailored sealing for portions that contain confidential business and competitive information (redactions on pages 13–14, 19–21, 23 and Exhibits K, O, P, Q) to prevent competitive harm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable sealing standard | Seal requests must meet the court's standards; Plaintiff emphasized public access where applicable | Daubert-related materials require "compelling reasons" to seal | Court applied the "compelling reasons" standard for these materials |
| Sealing of documents Plaintiff designated confidential (Exs. R1, R2; redaction at p.22) | Laatz does not request sealing of these items | Defendants sought sealing as confidential | Denied—Plaintiff does not seek sealing |
| Sealing of Page 12 redactions and Exhibits G, I, J (technical operation details) | Info already publicly disclosed; should remain public | Info is confidential technical operation detail of Design Tool/servers | Denied—information already publicly available on docket |
| Sealing of redactions pp.13–14, 19–21, 23 and Exhibits K, O, P, Q (business/financial data) | Plaintiff: defendants failed to meet evidentiary showing; terms are general | Defendants: disclosure would reveal sensitive competitive and financial data causing harm | Granted in part—court sealed narrowly tailored business/financial metrics and related damages calculations; other sealing requests denied as specified |
Key Cases Cited
- Kamakana v. City & Cty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (strong presumption of public access; "compelling reasons" required to seal judicial records attached to dispositive motions)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (presumption of access to judicial records)
- Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092 (9th Cir. 2016) (distinguishes compelling-reasons standard from Rule 26(c) good-cause standard)
- Phillips ex rel. Estates of Byrd v. Gen. Motors Corp., 307 F.3d 1206 (9th Cir. 2002) (Rule 26(c) requires particularized showing of good cause to seal non-dispositive materials)
- Beckman Indus., Inc. v. Int'l Ins. Co., 966 F.2d 470 (9th Cir. 1992) (broad, unsubstantiated allegations of harm insufficient to justify sealing)
- In re Elec. Arts, [citation="298 F. App'x 568"] (9th Cir. 2008) (business information that would harm competitive strategy can justify sealing)
- In re Google Location Hist. Litig., 514 F. Supp. 3d 1147 (N.D. Cal. 2021) (examples of sealable trade secrets and detailed financial/product information)