Reported / Citable
Background
Komorebi Advisors, LLC, doing business as InfiniWell, filed an emergency application for a temporary restraining order and preliminary injunction on July 8, 2026. The next day, after the court directed defendants Spray Labs, LLC and Spritz Health, LLC to respond that night, the defendants filed an appendix under seal without first requesting permission.
Defendants also filed under seal, without prior leave, a response to Komorebi’s request for expedited discovery and a preservation order. They later moved for leave to maintain public versions of both filings in redacted form.
The Court’s Holding
Judge Karen Gren Scholer granted defendants’ motion for leave to file the appendix and response with the proposed redactions. The appendix contained sensitive trade-secret information concerning Spray Labs’s formulation of the BPC-157 spray at issue, while the response included information related to national security.
Applying the Fifth Circuit’s demanding public-access standard for judicial records, the court concluded that the proposed redactions were narrowly tailored. The court held that redaction, rather than wholesale sealing, appropriately protected the sensitive material while preserving public access to the remainder of the filings.
Key Takeaways
- Parties generally must obtain judicial permission before filing materials under seal when no statute or rule independently authorizes sealing.
- Trade secrets and information implicating national security can outweigh the public’s common-law right of access when disclosure would cause competitive or other sensitive harm.
- Narrowly tailored redactions are the preferred, least restrictive alternative to sealing judicial records.
Why It Matters
The order reinforces the Northern District of Texas’s presumption of public access to court records and its requirement for a document-specific justification for withholding information. Even where sensitive business and national-security information is involved, the court expects parties to use targeted redactions rather than blanket sealing.