Another party has filed its own updated redaction motion in its lawsuit against State Farm and Safelite/Safelite Solutions over alleged trade secret misappropriation.
Like the insurer and third-party administrator (TPA), LYNX has filed a more detailed motion to redact certain details from the lawsuit documents.
LYNX, State Farm and Safelite/Safelite Solutions had moved for redaction early in the lawsuit, but Judge Jonathan Hawley of the U.S. District Court of Central Illinois, Peoria Division, denied the requests on August 27. The companies had 30 days after that to refile motions that included more details about the information in question, along with more precise and applicable legal reasoning. The information remained redacted in the meantime
The new filing from LYNX puts the redacted details into three categories: trade secret information, confidential pricing information and personal information.
“Disclosure of this information would either risk competitive harm or an unnecessary invasion of privacy,” the filing says. “…the interest in protecting this information from public disclosure outweighs the public’s right to access it.”
Trade Secret Information
According to the document filed by LYNX, the trade secrets to redact include “a compilation of all the auto glass service provider information entered into its METRYX registry.” LYNX says the registry “years to create,” and isn’t just a compilation of publicly available data, as the other parties argued, so it would hurt the company to have others access it. LYNX also labels its pricing strategy and a list of its customers, which include multiple insurers, as “trade secrets.”
“If this information does not remain sealed, it could be used by other competitors, like Safelite, to develop their own products and to address customer segments that LYNX targets,” the document says. “Moreover, disclosing the actual names of LYNX’s customers would enable LYNX’s competitors to compete directly with LYNX.”
Confidential Pricing Information
According to LYNX’s motion, the pricing information listed in various court documents from the case discloses “the precise term and timing of price escalations that LYNX and State Farm negotiated after careful analysis.” Revealing these details would mean LYNX’s competitors could figure out the company’s bargaining approach and provide margins and “exploit that information when competing for the same customer,” the motion says.
Personal Information
LYNX also has moved to redact the email addresses and signatures of its counsel and the employees of all parties.
“[Their privacy] would be jeopardized if their unique personal identifiers were made publicly accessible,” the document says. “Failing to seal this information could lead to misuse, identity theft, forgery or other fraud.”
The Public’s Right to Know?
Throughout the motion, LYNX maintains that keeping this information redacted would not hinder the public’s right to access court proceedings and lawsuit information.
“The public does not need access to the details of the trade secret information LYNX is seeking to seal to determine what this lawsuit is about,” the document says. “Rather, the parties’ dispute can be understood by reviewing the public documents that have been filed to date in this matter, a majority of which are not redacted and contain general references to trade secret information LYNX seeks to protect.”
LYNX also filed responses to State Farm and Safelite/Safelite Solutions’ redaction motions, which glassBYTEs/AGRR will review in the next glassBYTEs e-newsletter.


