ONYX ENTERPRISES CANADA INC. v. STANISLAV ROYZENSHTEYN, 3:23-cv-02913

Onyx Enterprises Canada Inc. filed three motions to seal portions of complaints and exhibits, as well as portions of defendants’ memorandum of law, in a federal civil case.
The motions to seal followed a court order that had previously denied sealing for lack of specificity and required Onyx to more clearly articulate its basis for seeking sealing.
Onyx based its motions primarily on earlier state court orders to seal similar information and confidentiality/nondisclosure agreements with third parties.
The court emphasized the strong presumption of public access to judicial records and the movant’s burden under Local Civil Rule 5.3 to justify sealing with particularity.
The district court reviewed the adequacy of Onyx's justifications under both federal law and the local rule, determined they were insufficient, and granted Onyx leave to supplement its filings.
The court noted some materials at issue may already be publicly available or previously unsealed, further undermining the sealing requests.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Whether prior state court sealing/confidentiality orders justify sealing in federal court	Prior state orders require confidentiality, and breaching them would subject parties to sanctions	Reliance on prior state sealing orders is insufficient without specific new justification	State orders and confidentiality agreements alone do not justify sealing under federal standards
Whether specific injury must be shown to seal materials	Onyx claims potential litigation, sanctions, or breach of agreements if not sealed	No specific, concrete injury alleged that meets federal standards	Specific, clearly defined injury must be articulated; vague claims insufficient
Whether public access presumption can be overridden by confidentiality agreements	Materials are covered by NDAs and confidentiality pacts, so must remain sealed	Confidential designations alone are not enough for sealing	Merely being confidential/subject to NDA is not enough; must meet Rule 5.3(c) standards
Whether materials already public can be sealed	Seeks to seal certain exhibits and filings, including ones already filed publicly	Such materials cannot be sealed if already public	Documents already public or available cannot be sealed due to lack of injury

None listed with official reporter citations in the provided text (all citations are to F. Supp. or use WL references, which do not satisfy the requested format).