Lupin Ltd. v. Salix Pharmaceuticals, Inc., 1:22-cv-07656

Defendants Salix Pharmaceuticals and Bausch Health US are seeking the court's permission to redact trade secret information from a document filed as Dkt. 82-1.
The document in question is an Exhibit attached to a Letter of Request addressed to Italian authorities, relating to the manufacturing specifications for rifaximin (an active pharmaceutical ingredient).
The redacted information includes API specifications and proprietary process flow sheets, which are considered trade secrets under FDA and prior court rulings.
The trade secrets have been previously protected under a court-ordered Protective Order and designated confidential during discovery.
Plaintiff Lupin Ltd. does not object to Defendants' proposed redactions.
The primary legal issue is whether this Exhibit, used only for foreign discovery and not central to any dispositive motion, should be treated as a judicial document subject to a presumption of public access under the Second Circuit standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should trade secret info in Dkt. 82-1 be sealed?	No objection	Redactions protect trade secrets	Redactions permitted
Is Exhibit a "judicial document" under access doctrine?	N/A	Not a judicial document	Presumption of access does not apply
If access applies, should it outweigh privacy interest?	N/A	Privacy interests outweigh	Trade secrets protected from access
Should foreign discovery material be public?	N/A	Exhibit aids foreign discovery	Public access is weak here

Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (articulates standard for sealing documents and presumption of public access)
Appleton v. Food & Drug Admin., 451 F. Supp. 2d 129 (D.D.C. 2006) (establishes that drug manufacturing secrets are protectable trade secrets)
United States v. Smith, 985 F. Supp. 2d 506 (S.D.N.Y. 2013) (discovery materials linked to non-dispositive issues not entitled to public access)