Vasudevan Software, Inc. v. MicroStrategy, Inc., 3:11-cv-06637

VSI moves to seal portions of MicroStrategy’s reply and three attached exhibits.
The court applies the strong presumption of public access to judicial records related to dispositive motions.
To seal, the moving party must overcome with a particularized showing of compelling reasons under Kamakana and related rules.
For nondispositive material, the lower good cause standard under Fed. R. Civ. P. 26(c) applies with particularized prejudice showing.
Civil Local Rule 79-5 requires narrowly tailored sealing and specific procedural steps; blanket protective orders are insufficient.
The court finds VSI failed to provide a particularized harm showing or narrow tailoring for the three exhibits and redactions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a strong presumption of access applies to the sealed materials	VSI argues for sealing based on confidential business information	MicroStrategy contends need to seal due to harm to business interests	Strong presumption applies; burden on sealant to show compelling reasons
Whether Exhibits 1–3 and redactions meet the particularized harm standard	Exhibits contain sensitive financial data and pricing terms warrant sealing	Redactions and disclosure could reveal pricing and revenues harms to business	Not sufficiently particularized; overbroad redactions; Exhibit 2 may seal pricing terms only

Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (strong presumption of disclosure for judicial records; compelling reasons required)
In re Electronic Arts, Inc., 298 Fed. Appx. 568 (9th Cir. 2008) (limits on sealing; referenced for protective orders and redaction standards)