C. Trade secrets or sensitive business information


Courts have allowed limited closures in order to protect trade secrets or other sensitive business information. Though it did not announce “a rule that the presence of trade secrets will in every case and at all events justify the closure of a hearing,” the Eighth Circuit affirmed the closure of civil court proceedings and the sealing of “a small portion” of the transcript where “trade secrets were in fact involved, and … substantial damage to [a party’s] property rights in these secrets would have occurred had the hearing not been closed.” In re Iowa Freedom of Information Council, 724 F.2d 658, 661, 664 (8th Cir. 1983).

6th Cir.