Naula Ndugga v. Bloomberg L.P.
1:20-cv-07464
| S.D.N.Y. | Aug 11, 2025Background
- Plaintiffs brought an employment-related action against Bloomberg L.P. in the Southern District of New York.
- At issue were motions to seal or redact documents filed in relation to both class certification and a Daubert motion seeking to exclude plaintiffs’ expert.
- Bloomberg sought to keep certain compensation and human resources information, including details about algorithms and specific employees, confidential.
- Past sealing of similar documents had occurred, but prior decisions happened during discovery disputes (where public access carries less weight).
- The present motions involve documents that court recognizes as "judicial documents" with a strong presumption of public access under both common law and the First Amendment.
- The court evaluated the adequacy of Bloomberg's justifications for sealing versus the public’s right to access court filings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether documents related to Daubert/class cert. may be sealed/redacted | Public access is presumptively strong; sealing should be narrow | Confidential business information and employee data require protection | Strong presumption of access; only narrow categories (e.g., input numbers, PII, sensitive HR data) may be redacted |
| Sufficiency of Bloomberg’s justification for sealing | General confidentiality claims are too vague | Asserts treatment as proprietary/business secret suffices | Court finds Bloomberg’s justifications conclusory; requires particularized, specific harm |
| Previous sealing rulings in discovery apply here | Discovery rulings shouldn't govern substantive motions | Prior practice should allow continued sealing | Prior discovery sealing irrelevant; substantive motions require stricter standard |
| Allowing amendments/further specific sealing requests | Court should allow renewed, targeted arguments | Seeks opportunity for more focused redactions | Court grants limited opportunity for more specific, fact-based sealing requests |
Key Cases Cited
- Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (establishes presumption of public access for judicial documents)
- In re Parmalat Sec. Litig., 258 F.R.D. 236 (S.D.N.Y. 2009) (party must show specific injury from disclosure, not just broad allegations)
- Tropical Sails Corp. v. Yext, Inc., 2016 WL 1451548 (S.D.N.Y. 2016) (class certification filings subject to the First Amendment framework) [INCLUDE ONLY IF IT HAD A PRINT CITATION, BUT DOES NOT, SO OMIT]