Sara Hadi v. Toyota Motor Corporation
2:23-cv-09613
| C.D. Cal. | Nov 7, 2024Background
- The case involves a putative class action brought by Yan Dong, Sara Hadi, and Jun Imaizumi against Toyota Motor Sales, U.S.A., Inc. and Toyota Motor North America, Inc. in the Central District of California.
- The parties jointly sought entry of a Stipulated Protective Order to govern the exchange and handling of confidential and proprietary materials during pre-trial discovery.
- The Order defines categories of protected information, including "Confidential," "Highly Confidential," and "Personally Identifiable Information," with special rules for designating and limiting access.
- There are detailed procedures for challenging or defending confidentiality designations, as well as for handling inadvertent disclosure or unauthorized dissemination of protected materials.
- The Order establishes security protocols for storage, transmission, and review of protected material and explicitly restricts use of public AI tools for processing such data without explicit permission.
- The court approved the Stipulated Protective Order, which remains in effect throughout litigation and beyond, with specified protocols for return or destruction of protected information post-litigation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Need for Protective Order | Discovery will involve confidential and private data | Discovery will involve confidential and private data | Stipulated Protective Order granted |
| Scope and Justification for Confidentiality | Order should broadly protect non-public, sensitive info | Only items with good reason for confidentiality merit protection | Only properly justified info may be protected |
| Challenging Confidentiality Designations | Allow challenges and fairness in designation process | Support challenge process but protect true secrets | Clear process established; burden on designator |
| Use of Protected Material in Filings | Allow seal for real confidential matters | Support sealing only for actual confidential info | Good cause or compelling reasons required; not automatic |
Key Cases Cited
- Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (articulates the good cause and compelling reasons standards for sealing court records)
- Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206 (9th Cir. 2002) (discusses requirements for protective orders and public access to court documents)
- Pintos v. Pac. Creditors Ass'n, 605 F.3d 665 (9th Cir. 2010) (distinguishes standards for sealing dispositive vs. non-dispositive motions)