Lonza Greenwood LLC v. Natals, Inc.
1:25-cv-06319
S.D.N.Y.Aug 20, 2025Background
- Plaintiff Lonza Greenwood LLC filed suit against Defendant Natals, Inc. (doing business as Ritual), and moved for a preliminary injunction.
- Shortly thereafter, Lonza also moved for an order to show cause, initiating a briefing schedule regarding the preliminary injunction.
- Ritual sought permission to file certain documents under seal, including its Sales Agreement with Lonza, clinical trial documents, an internal PowerPoint deck from Lonza, and a slide deck on an unannounced product.
- Ritual argued that the documents contain sensitive and proprietary business information, including trade secrets, pricing, and product strategies, which if disclosed, could harm its competitive position.
- The Court was tasked with balancing the presumption of public access to judicial documents against the competing privacy and business interests asserted by Ritual.
- Judge Engelmayor granted Ritual’s motion, allowing redacted public filing and sealed unredacted versions of the exhibits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exhibits should be sealed or publicly filed | Exhibits contain plaintiff's trade secrets and confidential info | Disclosure would harm competitive standing due to proprietary business info | Granted defendant’s request to seal/redact |
| Application of common law and First Amendment right of access | Public’s right to access judicial documents | Sealing warranted due to privacy and business interests | Privacy interests override access presumption |
| Whether sealing is narrowly tailored | Plaintiff claims necessity to protect trade secrets | Defendant seeks narrow sealing focused only on sensitive content | Court found request properly tailored |
| Harm from public disclosure | Public disclosure could harm competitive position | Public disclosure would undermine competitive edge and strategies | Court agrees harm justifies sealing |
Key Cases Cited
- Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (establishes three-part test for access to judicial documents and balancing of privacy vs. public interest in sealing)
- Dodona I, LLC v. Goldman, Sachs & Co., 119 F. Supp. 3d 152 (S.D.N.Y. 2015) (recognizes sealing of proprietary business information and trade secrets over public access)