Calhoun et al v. Google LLC, No. 4:2020cv05146 - Document 768 (N.D. Cal. 2022)
Court Description: ORDER denying 716 Administrative Motion to File Under Seal; granting 619 621 630 632 634 636 651 690 694 704 708 713 718 739 751 753 757 761 764 Administrative Motions to File Under Seal. Signed by Judge Susan van Keulen on 7/15/2022. (svklc1, COURT STAFF) (Filed on 7/15/2022)
Download PDF
<![CDATA[
Calhoun et al v. Google LLC Doc. 768 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 1 of 28 1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 PATRICK CALHOUN, et al., Plaintiffs, 8 ORDER ON ADMINISTRATIVE MOTIONS FOR LEAVE TO FILE UNDER SEAL 9 10 v. United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 Case No. 20-cv-05146-YGR (SVK) GOOGLE LLC, Re: Dkt. Nos. 619, 621, 630, 632, 634, 636, 651, 690, 694, 704, 708, 713, 716, 718, 739, 751, 753, 757, 761, 764 Defendant. Before the Court are several administrative motions to file under seal materials associated with discovery disputes in this case. Dkt. 619, 621, 630, 632, 634, 636, 651, 690, 694, 704, 708, 713, 716, 718, 739, 751, 753, 757, 761, 764; see also Dkt. 631, 643, 707, 729, 731, 755, 765 (declarations in support of motions to seal). Courts recognize a “general right to inspect and copy public records and documents, including judicial records and documents.” Kamakana v. City & Cnty. Of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (quoting Nixon v. Warner Communs., Inc., 435 U.S. 589, 597 & n.7 21 (1978)). A request to seal court records therefore starts with a “strong presumption in favor of 22 access.” Kamakana, 447 F.3d at 1178 (quoting Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 23 1122, 1135 (9th Cir. 2003)). The standard for overcoming the presumption of public access to 24 court records depends on the purpose for which the records are filed with the court. A party 25 seeking to seal court records relating to motions that are “more than tangentially related to the 26 underlying cause of action” must demonstrate “compelling reasons” that support secrecy. Ctr. For 27 Auto Safety v. Chrysler Grp., 809 F.3d 1092, 1099 (9th Cir. 2016). For records attached to 28 motions that re “not related, or only tangentially related, to the merits of the case,” the lower Dockets.Justia.com Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 2 of 28 1 “good cause” standard of Rule 26(c) applies. Id.; see also Kamakana, 447 F.3d at 1179. A party 2 moving to seal court records must also comply with the procedures established by Civil Local 3 Rule 79-5. 4 Here, the “good cause” standard applies because the information the parties seek to seal 5 was submitted to the Court in connection with discovery-related motions, rather than a motion that 6 concerns the merits of the case. The Court may reach different conclusions regarding sealing 7 these documents under different standards or in a different context. Having considered the 8 motions to seal, supporting declarations, and the pleadings on file, and good cause appearing, the 9 Court ORDERS as follows: 10 1. United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Document Sought to be Sealed Google LLC’s Objections to Special Master’s Report and Recommendation on Referred Discovery Issues (Preservation Plan) Dkt. 619 Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to the portions at: The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. Pages: 3:3-7, 3:1019, 4:1-19, 5:1-18, 6:1, 6:5-17, 7:1-3, 7:6, 7:9, 7:11, 7:1314, 7:16-18, 8:1-3, 8:5-7, 8:9-11, 8:1415, 8:17-19, 9:1-3, 9:5-7, 9:9-11, 9:1319, 10:1-18, 11:1-11 26 27 28 2 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 3 of 28 1 2 3 4 5 6 7 8 9 2. Dkt. 621, 630; see also Dkt. 631 Document Court’s Ruling on Sought to be Motion to Seal Sealed Plaintiffs’ GRANTED as to the Objections to portions at: (and Motion to Modify) the Pages 3:4, 3:8, 5:9Special Master’s 10, 5:14, 5:22-24, Sealed 6:1-2, 6:10, 6:14 Recommendation s and Order Dated April 4, 2022 (Dkt. 604) 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit A1 - Joint GRANTED as to the Submission re portions at: Preservation Proposal PDF Pages 2-7, 10 Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, as well as internal metrics, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 3 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 4 of 28 1 2 3 4 5 6 Exhibit A2 Declaration of Zubair Shafiq ISO Plaintiff’s Objections to and Motion to Modify Special Master’s April 4, 2022 Report and Recommendation s GRANTED as to the portions at: Pages 1:17-18, 1:19, 1:27, 2:7-14, 2:18, 2:22-23, 2:25, 2:27, 3:1-3, 3:17 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3. Document Sought to be Sealed Plaintiffs’ Response to Google’s Objections to Special Master’s Sealed Recommendations and Order Dated April 4, 2022 The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, identifiers, data signals, and logs, and their proprietary functionalities, as well as internal metrics, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. Dkt. 632; see also Dkt. 643 Court’s Ruling on Motion to Seal GRANTED as to the portions at: Reason(s) for Court’s Ruling Pages 1:6-8, 1:11, 11:19, 1:21, 1:23, 1:27, 2:1, 2:911, 2:16, 2:18, 2:20, 2:23, 2:25, 2:27-28, 3:13, 3:5-6, 3:8, 3:10, 3:1213, 3:15-22, 3:24-25, 3:27-28, 4:1-23, 4:25-28, 5:1-13, 5:16, 5:22-27, 6:1-2, 6:6, 6:8, 6:10-11, 6:12, 6:14-27, 7:1-11, 7:14322, 7:28, 8:1-2, 8:15, 8:17 26 27 28 4 The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, as well as internal metrics, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 5 of 28 1 2 3 4 5 6 7 8 Declaration of Zubair Shafiq in Support of Plaintiffs’ response to Google’s Objections to Special Master’s April 4, 2022 Report and Recommendations GRANTED as to the portions at: Pages 2:7, 2:10, 2:13-17, 2:24-25, 3:1-3, 3:5-7, 3:10-12, 3:14, 3:16-27, 4:1-27, 5:1, 5:3, 5:7-10, 5:13, 5:15-20, 5:22-24, 5:26-27, 6:2, 6:4-26, 6:27, 7:1-10 9 10 United States District Court Northern District of California 11 12 13 14 15 16 cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 17 18 4. Dkt. 634 19 20 21 22 23 24 25 26 Document Sought to be Sealed Google’s Responses Court’s Ruling on Motion to Seal GRANTED as to the portions at: Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and Pages: 1:19-21, 1:23-26, 2:17, 2:20-23, 3:9, 3:2223, 4:1-2, 4:4-6, 4:8-9, 4:21-23, 4:27-28, 5:28, 6:1-4, 6:14-15, 7:15-18, 7:24-26, 8:2-6 27 28 5 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 6 of 28 business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and 1 2 3 4 5 6 7 Trebicka Exhibit 1 8 GRANTED as to the portions at: Pages: Redacted in its Entirety 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 Trebicka Exhibit 2 GRANTED as to the portions at: 22 23 Pages: Redacted in its Entirety 24 25 26 27 28 6 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 7 of 28 1 2 3 4 5 6 7 8 Harting Declaration Pages: 1:20-21, 1:23-24, 2:4-6, 2:12-14, 2:16-28, 3:1-20. 3:22-24, 3:26-27, 4:1-5, 4:7-9, 4;11-22, 4:28, 5:1-2, 5:4-6 9 10 11 United States District Court Northern District of California GRANTED as to the portions at: 12 13 14 15 16 17 18 19 20 21 //// 22 //// 23 //// 24 //// 25 //// 26 //// 27 //// 28 //// 7 business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 8 of 28 1 2 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 5. Document Sought to be Sealed Dkt. No. 632-2: Plaintiffs’ Response to Google’s Objections to the Special Master’s Sealed Recommendations and Order Dated April 4, 2022 (Dkt. No. 604) Dkt. No. 632-4: Supplemental Declaration of Dr. Zubair Shafiq Dkt. 636 Court’s Ruling on Motion to Seal GRANTED as to redactions on Page 6, lines 15-16 Reason(s) for Court’s Ruling GRANTED as to redactions on Page 6, line 5 The proposed redactions are narrowly tailored and seek to protect only material that summarizes, reflects, or otherwise discusses Plaintiffs’ browsing history and related data and information, which Plaintiffs have not made otherwise available to the public. The proposed redactions are narrowly tailored and seek to protect only material that summarizes, reflects, or otherwise discusses Plaintiffs’ browsing history and related data and information, which Plaintiffs have not made otherwise available to the public. 12 13 6. 14 15 16 Document Sought to be Sealed Google’s Response Dkt. 651 Court’s Ruling on Motion to Seal GRANTED as to the portions at: Reason(s) for Court’s Ruling 17 18 19 20 21 Page 2 Lines 7, 14, 16, 17, 21, 25; Page 3 Lines 1-3, 6, 8, 11-12, 13, 16, 18, 20, 26-27; Page 4 Lines 1, 3, 4, 6, 11, 13, 16, 20, 21, 22, 23, 24; Page 5 Line 6. 22 23 24 25 26 27 28 8 The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 9 of 28 1 2 3 4 Trebicka Declaration Report and Recommendations GRANTED as to the portions at: Trebicka Exhibit 2 GRANTED as to the portions at: 5 Page 1 Lines 17-18, 2527; Page 2 Lines 3, 1112. 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 Page 2 Line 2; Page 3 Lines 14, 15, 16, 18. 19 20 21 22 23 24 25 26 27 28 9 information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 10 of 28 1 2 Trebicka Exhibit 3 GRANTED as to the portions at: 3 Pages 1, 2. 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 Trebicka Exhibit 4 GRANTED as to the document in its entirety. 17 18 19 20 21 22 23 24 25 26 27 28 10 information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 11 of 28 1 2 Trebicka Exhibit 5 GRANTED as to the document in its entirety. Trebicka Exhibit 6 GRANTED as to the portions at: 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 Pages 1, 2, 3, 4, 5. 18 19 20 21 22 23 24 25 26 27 28 11 information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 12 of 28 1 2 Trebicka Exhibit 7 GRANTED as to the portions at: 3 Pages 1, 2. 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 Trebicka Exhibit 8 GRANTED as to the portions at: Page 2 Lines 12-15; Page 3 Lines 7-10. 19 20 21 22 23 24 25 26 27 28 12 information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 13 of 28 information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the 1 2 Trebicka Exhibit 9 GRANTED as to the portions at: 3 Page 1. 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 Trebicka Exhibit 10 GRANTED as to the portions at: Pages 1-2. 18 19 20 21 22 23 24 25 26 27 28 13 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 14 of 28 information to compromise Google’s internal practices relating to competing products. 1 2 7. Dkt. 690; see also Dkt. 707 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 Documents Sought to be Sealed Plaintiffs’ Objections and Motion to Modify Special Master R&R Re: Modified Preservation Plan (Dkt. 665) Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to the portions at: Narrowly tailored to protect confidential technical information regarding sensitive features of Google’s internal systems and operations, including the various types of data sources which include information related to Google’s internal project, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. 1:9-11, 1:17, 1:19, 5:1820, 5:23-24, 6:2, 6:8, 6:10, 6:18, 6:21-22, 7:1, 7:3-5, 7:8, 7:23, 8:2-3, 8:17-19, 8:22-24, 9:1-4, 9:6, 9:9-12, 9:13-21, 9:27, 10:8-10 12 13 14 15 16 Declaration of GRANTED as to the David Straite in portions at: Support of Plaintiffs’ 1:14-15, 1:17-21 Objections and Motion to Modify Narrowly tailored to protect confidential technical information regarding sensitive features of Google’s internal systems and operations, including the various types of data sources which include information related to Google’s internal project, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Narrowly tailored to protect confidential technical information regarding sensitive features of Google’s internal systems and operations, including the various types of data sources which include information related to Google’s internal data signals and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Narrowly tailored to protect confidential technical information regarding sensitive features of Google’s internal systems and operations, including the various types of 17 18 19 20 Exhibit A (GOOG- GRANTED as to the CALH-01170421) portions at: 21 Redacted in its entirety 22 23 24 25 26 27 28 Exhibit B (GOOG- GRANTED as to the CABR-00893711) portions at: Redacted in its entirety 14 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 15 of 28 data sources which include information related to proprietary functionalities of Google’s services, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Narrowly tailored to protect confidential technical information regarding sensitive features of Google’s internal systems and operations, including the various types of data sources which include information related to Google’s internal projects and services, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. 1 2 3 4 5 Exhibit C (GOOG- GRANTED as to the CABR-00096597) portions at: Redacted in its entirety 6 7 8 9 10 United States District Court Northern District of California 11 8. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Documents Sought to be Sealed Google’s Objections to Special Master’s Report and Recommendation Regarding Calhoun Modified Preservation Plan (Dkts. 665, 666) Dkt. 694 Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to the portions at: The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive Pages: 2:12-15, 2:19-20, features of Google’s internal systems and 2:22-27, 3:1-2, 3:7-14, operations, including various types of internal 3:16-17, 3:19-20, 3:22databases and their proprietary 23, 3:26-27, 4:2-7, 4:9functionalities, data size, as well as internal 11, 4:17-20, 4:27-28, 5:1- metrics, that Google maintains as confidential 5, 5:7, 5:23-28, 6:1, 6:3- in the ordinary course of its business and is 4, 6:7, 6:9, 6:14-18. 6:20, not generally known to the public or Google’s 6:22, 7:1, 7:20-21, 7:23- competitors. Such confidential and 24, 7:27. proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 28 15 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 16 of 28 1 Declaration Patrick Quaid of GRANTED as to the portions at: 2 Pages: 1:11, 1:13, 1:15, 1:19-20, 1:25, 2:5-6. 2:9, 2:14-20, 2:22-28, 3:3-6, 3:9-12. 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 9. Documents Sought to be Sealed Google LLC’s Administrative Motion for Clarification of June 13, 2022 Discovery Order (Dkt. 700) The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of internal databases and their proprietary functionalities, data size, as well as internal metrics, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. Dkt. 704 Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to the portions at: The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of internal logs and databases and their proprietary structures and functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google Pages: 2:14, 2:16-17, 2:21, 2:22, 2:24, 3:23, 4:6, 4:12, 4:13, 4:22 22 23 24 25 26 27 28 16 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 17 of 28 at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 10. Dkt. 708; see also Dkt. 729 4 5 6 7 8 9 10 United States District Court Northern District of California 11 Documents Sought to be Sealed Plaintiffs’ Response to Google’s Objections (Dkt. No. 695) to Special Master’s Modified Preservation Plan (Dkt. Nos. 665, 666) Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to: Portions at: Pages 1:3, 1:6, 1:23, 1:26, 2:2, 2:5-7, 2:9, 2:12, 2:15, 2:18-19, 2:21, 2:24, 2:2628, 3:1, 3:4, 3:6-8, 3:17-18, 4:1, 4:3-17, 4:19-20, 4:26, 4:28-5:1, 5:3, 5:6, 5:12-16, 5:18-19, 5:21-22, 5:26 12 13 14 15 16 17 18 19 20 21 22 23 24 Declaration of GRANTED as to: David Straite in Portions at: Support of Pages 1:12, 1:14 Plaintiffs’ Response to Google’s Objections (Dkt. No. 695) 25 26 27 28 17 The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including internal data signals, logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including internal logs, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 18 of 28 1 2 3 4 5 6 Exhibit A GRANTED as to: (8/4/21 Harting Depo Portions at: Tr. Excerpts) Pages 15:8, 139:11, 139:15, 139:20, 139:24, 140:6, 140:8, 140:12, 140:19-21, 140:25-141:2, 141:9, 141:16-17, 264:14-15, 264:19, 264:23, 265:1-2, 265:6, 265:8, 265:16, 265:19 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 Exhibit B (5/11/22 Google Letter to SM) GRANTED as to: Portions at: Pages 1-5 21 22 23 24 25 26 27 28 18 competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including internal data signals, logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various internal projects, data signals, logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 19 of 28 competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various internal projects, data signals, logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 Exhibit C (Exhibit 11 GRANTED as to: from Portions at: 4/9/21 Monsees Deposition) Pages 1-2 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 11. Dkt. 713 18 19 20 21 22 23 24 25 26 27 28 Documents Sought to be Sealed Google’s Response to Plaintiffs’ Objections to Special Master’s Report and Recommendation re Calhoun Modified Preservation Plan Court’s Ruling on Motion to Seal Reason(s) for Court’s Ruling GRANTED as to the portions at: The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive Pages: 1:12, 1:15-19, features of Google’s internal systems and 2:21-23, 3:9-15, 4:13-20, operations, including various types of 4:25, 5:1, 5:6-9, 5:17, Google’s internal projects, data signals, and 5:24, 5:26-27, 6:2-3, 6:7, logs and their proprietary functionalities, that 6:9, 6:13, 6:16-25, 7:6-9, Google maintains as confidential in the 7:12-13, 7:15-19, 7:24ordinary course of its business and is not 25, 8:1, 8:3-9, 8:11-14, generally known to the public or Google’s 8:18, 8:21-26, 9;11, 9:14- competitors. Such confidential and 28, 9:2-28, 10:2-28, 11:2- proprietary information reveals Google’s 28, 13:2, 13:14, 13:16internal strategies, system designs, and business practices for operating and 19 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 20 of 28 18, 13:20, 13:23-27, 14:2-5 1 2 3 4 5 6 7 Declaration Bryant Chan 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration Tracy Gao maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. of GRANTED as to the The information requested to be sealed portions at: contains Google’s confidential and proprietary information regarding sensitive Pages: 1:19-20, 1:28, features of Google’s internal systems and 2:8-9, 2:13-27, 3:2-3, operations, including various types of 3:8-12 Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. of GRANTED as to the The information requested to be sealed portions at: contains Google’s confidential and proprietary information regarding sensitive Pages: 1:8, 1:13-14, 1:24, features of Google’s internal systems and 1:28, 2:2-10, 2:13-15 operations, including various types of Google’s internal projects, data signals, and logs and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and 20 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 21 of 28 maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 6 7 12. 8 Documents Sought to be Sealed 9 10 United States District Court Northern District of California 11 12 13 14 15 16 Dkt. 716; see also Dkt. 731 Court’s Ruling on Motion to Seal Plaintiffs’ Response DENIED as to Redacted to Google’s Motion Portions at 3:11-13; 4:1-3 for Clarification (Dkt. 705) of the Court’s Third Order Compelling Google to Produce the Named Plaintiff Data (Dkt. 700) 13. 19 Google states that there is no Google confidential information that needs to be sealed in Plaintiffs’ Response to Google’s Motion for Clarification. Dkt. 731 ¶ 3. Dkt. 718 17 18 Reason(s) for Court’s Ruling Documents Sought to be Sealed Google’s Supplement Court’s Ruling on Motion to Seal Page 2 Lines 10, 13, 17, 19, 22 20 21 22 23 24 25 26 27 28 21 Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 22 of 28 practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 Proposed Order Page 1 Lines 7, 10 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 14. Dkt. 739 Documents Sought to Court’s Ruling on be Sealed Motion to Seal Google’s Notice of GRANTED as to the Errata re: Google portions at: LLC’s Response to Plaintiffs’ Objections 1:8-13 to Special Master’s Report and Recommendation (Dkt. 713-4). 25 26 27 28 22 Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal logs and data signals, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 23 of 28 disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 15. Dkt. 751 Documents Sought to Court’s Ruling on be Sealed Motion to Seal Google LLC’s GRANTED as to the Submission in portions at: Response to Dkt. 749 Page 1:1-4, 1:6-11, 1:15-22, 1:23-26 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Attachment A to GRANTED as to the Google’s Submission portions at: Redacted in its entirety 26 27 28 23 Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, and their proprietary functionalities, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects, data signals, and logs, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 24 of 28 proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 16. Dkt. 753; see also Dkt. 755, 765 Documents Sought to be Sealed Plaintiffs’ Response to Sealed Court Order dated July 5, 2022 (Dkt. No. 749) 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of David Straite in Support of Plaintiffs’ Response to Sealed Court Order dated July 5, 2022 (Dkt. Court’s Ruling on Motion to Seal GRANTED as to the portions highlighted in green at: Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including details related to i:12, 1:2-7, 1:20- Google’s internal projects and logs, that 21, 3:26-27 Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. GRANTED as to The information requested to be sealed the portions at: contains Google’s confidential and proprietary information regarding sensitive Pages: 1:15-16, features of Google’s internal systems and 1:20, 1:26, 2:2, operations, including details related to 24 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 25 of 28 1 No. 749) 2 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 Exhibit A 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit B 2:4-5, 2:8-9, 2:11- Google’s internal projects and logs, that 12, 3:1, 3:4, 3:9Google maintains as confidential in the 11 ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. GRANTED as to The information requested to be sealed the portions at: contains Google’s confidential and proprietary information regarding sensitive In its entirety features of Google’s internal systems and operations, including details related to Google’s internal projects, data signals, and logs, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. GRANTED as to The information requested to be sealed the portions at: contains Google’s confidential and proprietary information regarding sensitive In its entirety features of Google’s internal systems and operations, including details related to 25 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 26 of 28 Google’s internal projects, data signals, and logs, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including details related to Google’s internal projects and organizations, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 Exhibit C (GOOGCALH-00864584) GRANTED as to the portions at: 13 In its entirety 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17. Dkt. 757 Documents Sought to be Sealed Court’s Ruling on Motion to Seal 26 Reason(s) for Court’s Ruling Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 27 of 28 1 2 Google LLC’s GRANTED as to the Submission in entire document Response to Dkt. 756 3 4 5 6 7 8 9 10 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18. The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal data logging systems, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their data logging systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal data logging infrastructure. Dkt. 761 Documents Sought to Court’s Ruling on be Sealed Motion to Seal June 30, 2022 Hearing GRANTED as to the Transcript portions at: Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive 7:12, 7:17, 7:24, 8:17- features of Google’s internal systems and 18, 8:21, 9:5-12, 9:19, operations, including details related to 10:17-21, 13:25, 14:1- Google’s internal projects, internal databases, 12, 15:15, 15:23, data signals, and logs, and their proprietary 16:10-11, 16:20, 17:2, functionalities, data size, as well as internal 17:25, 18:7, 18:16, metrics, that Google maintains as confidential 19:4, 20:12, 20:15, in the ordinary course of its business and is 21:10, 23:9-12, 25:13, not generally known to the public or Google’s 26:15, 29:4, 29:25, competitors. Such confidential and 35:7, 35:19, 36:10, proprietary information reveals Google’s 36:15, 37:7, 38:2, internal strategies, system designs, and 38:12-17, 40:20, business practices for operating and 40:23, 44:23, 48:18, maintaining many of its services. Public 49:4, 49:8, 57:18 disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to 27 Case 4:20-cv-05146-YGR Document 768 Filed 07/15/22 Page 28 of 28 competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 1 2 3 4 5 6 7 8 9 10 19. Dkt. 764 Documents Court’s Ruling on Sought to be Motion to Seal Sealed Order Following GRANTED as to the June 30, 2022 portions at: Hearing on Preservation Plan Pages 1:15, 1:17, 1:23-28 United States District Court Northern District of California 11 12 13 14 15 16 17 18 19 20 21 Reason(s) for Court’s Ruling The information requested to be sealed contains Google’s confidential and proprietary information regarding sensitive features of Google’s internal systems and operations, including various types of Google’s internal projects logs, that Google maintains as confidential in the ordinary course of its business and is not generally known to the public or Google’s competitors. Such confidential and proprietary information reveals Google’s internal strategies, system designs, and business practices for operating and maintaining many of its services. Public disclosure of such confidential and proprietary information could affect Google’s competitive standing as competitors may alter their systems and practices relating to competing products. It may also place Google at an increased risk of cybersecurity threats, as third parties may seek to use the information to compromise Google’s internal practices relating to competing products. 22 23 24 25 26 Within 7 days of the date of this Order, Plaintiffs are ordered to file an unredacted version of Dkt. 717, in accordance with the Court’s denial of the motion to seal at Dkt. 716. SO ORDERED. Dated: July 15, 2022 27 SUSAN VAN KEULEN United States Magistrate Judge 28 28
]]>
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You
should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.
