With no explanation, chose the best option from "A", "B", "C" or "D". the certifications and may not furnish reports if “reasonable grounds” exist to believe that reports will be used impermissibly. 15 U.S.C. § 1681e(a). Under the plain terms of § 1681e(a), a subscriber’s certification cannot absolve the reporting agency of its independent obligation to verify the certification and determine that no reasonable grounds exist for suspecting impermissible use. Blanket certification cannot elimi nate all genuine issues of material fact with regard to Experian’s liability. C. Experian’s Motion to File Dom-ments Under Seal Two standards generally govern motions to seal documents like the one at issue here. First, a “compelling reasons” standard applies to most judicial records. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178 (9th Cir.2006) (<HOLDING>); Foltz v. State Farm Mut.Auto. Ins. Co., 331

A: recognizing that the party seeking attorney fees bears the burden of proving entitlement to those fees
B: holding that a party seeking to seal a judicial record  bears the burden of overcoming  the compelling reasons standard
C: holding that defendant bears burden of presenting compelling case that exercising jurisdiction over it would not be fair and just
D: holding that a party seeking a writ bears the burden of proving that it has no other means of attaining the relief such as by appeal
B.