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Zesty Paws LLC v. Nutramax Laboratories, Inc.
1:23-cv-10849
S.D.N.Y.
Jul 10, 2024
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Background

  • Zesty Paws LLC is engaged in litigation against Nutramax Laboratories and related entities.
  • Zesty Paws sought to file certain confidential sales and revenue data (contained in the Ooralath Declaration and attached exhibits) under seal, arguing these are private business records.
  • On March 15, 2024, Zesty Paws requested to seal these documents in their entirety due to the sensitive, non-public financial data involved.
  • The court previously determined that non-public financial results may be redacted, but denied Zesty Paws’ motion to seal the documents in full, instructing them to renew and narrow the request.
  • Zesty Paws submitted a renewed, limited motion seeking to redact only specific non-public data and to seal Exhibits A and B, which consist solely of that data.
  • On July 10, 2024, the court granted Zesty Paws’ request to restrict disclosure, requiring that a public, redacted version be filed by July 12, 2024.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether non-public financial data may be sealed or redacted from the Ooralath Declaration and attached exhibits Disclosure would harm competitive standing and involves confidential, private information Not specified in this opinion Request to seal/redact granted as to non-public sales data; limited redactions and sealing permitted

Key Cases Cited

  • Nixon v. Warner Comm., Inc., 435 U.S. 589 (balance between presumption of public access and protection of sensitive business information)
  • Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (test for access to judicial documents and balancing of interests)
  • Std. Inv. Chtd., Inc. v. Fin. Indus. Regulatory Auth., Ind., 347 F. App’x 615 (interests in protecting confidential business data can outweigh presumption of access)
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Case Details

Case Name: Zesty Paws LLC v. Nutramax Laboratories, Inc.
Court Name: District Court, S.D. New York
Date Published: Jul 10, 2024
Docket Number: 1:23-cv-10849
Court Abbreviation: S.D.N.Y.