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