Topnotch Innovations, LLC v. Dean, 2:20-cv-01384

TopNotch Innovations, LLC filed a redacted Motion for Preliminary Injunction and separately moved for leave to file an unredacted version under seal.
Plaintiff asserted the unredacted filing contains confidential financial information and confidential conversations with Defendant Mark Anthony Dean.
The magistrate judge applied the Sixth Circuit’s high standard: documents may be sealed only for the most compelling reasons and require detailed, document-by-document justification.
Plaintiff’s sealing motion offered only conclusory assertions of confidentiality and did not explain why disclosure would cause harm or show trade-secret status.
The court held that a parties’ agreement of confidentiality, standing alone, does not justify sealing and cited precedent requiring specific findings to justify nondisclosure.
The motion to file under seal was denied without prejudice; the court instructed any future sealing request to provide compelling, narrowly tailored justification demonstrating good cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether leave to file an unredacted preliminary-injunction filing under seal should be granted	TopNotch: filings contain confidential financial data and confidential conversations that should be sealed	Dean: (not argued in the record) implicit public-access interest; parties’ agreement alone insufficient	Denied without prejudice — plaintiff failed to provide compelling, specific reasons and document-by-document justification
Whether a parties’ confidentiality agreement alone justifies sealing	TopNotch: (implied) parties agreed to confidentiality	Dean: (and law) confidentiality agreements do not bind the court	Court: Agreement alone is inadequate; confidential terms do not automatically permit sealing
Standard and scope for sealing judicial records	TopNotch: broad confidentiality claim over financials and communications	Dean: public access presumption and Sixth Circuit ‘‘most compelling reasons’’ standard	Court: sealing requires compelling reasons, detailed analysis per document, and must be narrowly tailored; instructs refile with adequate support if desired

Shane Grp., Inc. v. Blue Cross Blue Shield of Michigan, 825 F.3d 299 (6th Cir. 2016) (documents may be sealed only for the most compelling reasons)
In re Knoxville News–Sentinel Co., 723 F.2d 470 (6th Cir. 1983) (public right of access to judicial records)
Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544 (7th Cir. 2002) (movant must analyze in detail, document-by-document, the propriety of secrecy)
Rudd Equip. Co., Inc. v. John Deere Constr. & Forestry Co., 834 F.3d 589 (6th Cir. 2016) (district court must set forth specific findings and conclusions to justify nondisclosure)
Brown & Williamson Tobacco Corp. v. F.T.C., 710 F.2d 1165 (6th Cir. 1983) (a confidentiality agreement between parties does not bind the court)