In the first reported case of its kind, the 4th U.S. Circuit
Court of Appeals this week overturned a federal district
court's order that allowed a company to proceed under a
pseudonym and to file all pleading related to a challenge of the
Consumer Product Safety Commission's (CPSC) online database
publication of a report of harm under seal. The case, Co. Doe
v. Public Citizen, 2014 U.S. App. LEXIS 7113, 2-3 (4th Cir.
2014), stemmed from a company's challenge to the CPSC's
publication of a report received on its database under the Consumer
Product Safety Improvement Act of 2008 (CPSIA), which allows for
publication of such reports unless a manufacturer objects that the
reports are materially inaccurate or confidential. 15 U.S.C. §
2055(c)(2). Materially inaccurate information is defined as
"false or misleading and which is so substantial and important
as to affect a reasonable consumer's decision making about the
product." 16 C.F.R. § 1102.26(a)(1). The
