From Araujo v. E. Mishan & Sons, Inc., decided Thursday by Judge John Cronan (S.D.N.Y.):
Plaintiff William Araujo filed a motion to seal the Court's Opinion and Order construing two terms in one of the claims of his patent….
Under "the First Amendment and the common law," the public has a "presumption of access to judicial records." The Second Circuit has broadly defined a "judicial document" as an "item that is relevant to the performance of the judicial function and useful in the judicial process." A document is relevant to the performance of the judicial function "if it would reasonably have the tendency to influence a district court's ruling on a motion or in the exercise of its supervisory powers." The public has a presumption of access to these documents "so that the federal courts have a measure of accountability and so that the public may have confidence in the administration of justice." …
Plaintiff concedes that the Opinion is a judicial document, as it obviously is…. [A] strong presumption of public access attaches to the Opinion.
Plaintiff argues that presumption is weak because this case is a "civil controversy between private individuals" which has not sparked "interest on the part of news media." But this is also true of most civil litigation cases. The fact that Plaintiff's case has not received significant media attention does not detract from the Opinion's role in the Court's exercise of its Article III power. Further, there may be a public interest in the Opinion as its discussion of the claim construction legal standard and subsequent analysis could serve as helpful authority for litigants and judges in future cases….
