Emerging Automotive LLC v. Kia Corporation

CourtDistrict Court, E.D. Texas
DecidedMarch 25, 2025
Docket2:23-cv-00437
StatusUnknown

This text of Emerging Automotive LLC v. Kia Corporation (Emerging Automotive LLC v. Kia Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emerging Automotive LLC v. Kia Corporation, (E.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

EMERGING AUTOMOTIVE LLC, § § Plaintiff, § § v. § CIVIL ACTION NO. 2:23-CV-00437-JRG § (LEAD CASE) KIA CORPORATION and KIA AMERICA, § INC., § § Defendants. § §

EMERGING AUTOMOTIVE LLC, § § Plaintiff, § § v. § CIVIL ACTION NO. 2:23-CV-00434-JRG § (MEMBER CASE) TOYOTA MOTOR NORTH AMERICA § INC., TOYOTA MOTOR SALES, U.S.A., § INC., and TOYOTA MOTOR § CORPORATION, § § Defendants. § §

MEMORANDUM OPINION AND ORDER Before the Court is the Motion for Entry of Protective Order (the “Motion”) filed by non- party Sherpa Technology Group, Inc. (“Sherpa”). (Dkt. No. 148.) Having considered the Motion and related briefing, the Court finds that it should be and hereby is GRANTED-IN-PART and DENIED-IN-PART. I. BACKGROUND Plaintiff Emerging Automotive LLC (“EA”) filed suit against Defendants Toyota Motor Corp.; Toyota Motor North America, Inc.; Toyota Motor Engineering & Manufacturing North America, Inc.; and Toyota Motor Sales, U.S.A., Inc. (collectively, “Toyota”) on September 20, 2023, alleging patent infringement. (Case No. 2:23-cv-00434-JRG, Dkt. No. 1.) On July 11, 2024, Toyota moved to compel EA’s negotiations for unconsummated licenses. (Dkt. No. 63.) The Court denied Toyota’s request, holding that “Ongoing or unconsummated settlement and licensing

negotiations with the patents-in-suit are not discoverable.” (Dkt. No. 94 (quoting Mondis Tech., Ltd. v. LG Elecs., Inc., 2011 WL 1714304, *5 (E.D. Tex. May 4, 2011)).) On November 7, 2024, Toyota served third-party subpoenas on Sherpa, including a request for production and noticing a deposition. (Dkt. No. 148 at 1; see also Dkt. Nos. 148-2, 148-3.) EA engaged Sherpa from 2017 to 2019 to monetize certain of EA’s patents, including three of the four asserted patents. (Dkt. No. 148 at 2; Dkt. No. 148-4.) Toyota’s subpoenas seek information about EA and Sherpa’s relationship to monetize EA’s patent portfolio. (See Dkt. Nos. 148-2, 148-3.) Sherpa filed the Motion on January 24, 2025, requesting that the Court preclude Toyota from deposing Sherpa regarding testimony that Sherpa asserts the Court has already ruled is not discoverable.1 (Dkt. No. 148 at 1.)

II. LEGAL STANDARD Rule 26(b)(1) governs the scope of discovery, providing that “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). Despite the broad nature of this rule, “discovery, like all matters of procedure, has ultimate and necessary boundaries.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978) (quoting Hickman v. Taylor, 329 U.S. 495, 507 (1947)). One boundary is that a party must show good cause to obtain a protective order. Fed. R. Civ. P. 26(c). Another boundary is that the Court must limit discovery if it

1 The Motion is limited to Toyota’s deposition subpoena and does not request any relief with respect to Toyota’s document subpoena. (See generally Dkt. No. 148.) determines that “(i) the discovery sought is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less burdensome or less expensive; (ii) the party seeking discovery has had ample opportunity by discovery in the action to obtain the information sought; or (iii) the proposed discovery is outside the scope permitted by Rule

26(b)(1).” Fed. R. Civ. P. 26(b)(2)(C). The movant for a protective order bears the burden “to show the necessity of its issuance, which contemplates a particular and specific demonstration of fact as distinguished from stereotyped and conclusory statements.” United States v. Garrett, 571 F.2d 1323, 1326 n.3 (5th Cir. 1978). III. DISCUSSION Sherpa argues that the Court should preclude Toyota from deposing Sherpa because Toyota seeks testimony that the Court has held is not discoverable. (Dkt. No. 148 at 4-5.) Sherpa also argues that to the extent the Court finds that Toyota seeks discoverable testimony, the Court should still preclude Toyota from deposing Sherpa because the testimony Toyota seeks is available through less burdensome means. (Id. at 5-6.)

A. Toyota’s Deposition Subpoena Seeks Discoverable Testimony Sherpa argues that Toyota seeks testimony that the Court has ruled is not discoverable. (Dkt. No. 148 at 4-5.) Sherpa asserts that EA “retained Sherpa as its agent to monetize its patents [and] Sherpa’s efforts did not lead to any consummated licenses or sales of the patents.” (Id. at 4.) Sherpa argues that Toyota seeks “testimony from Sherpa regarding Emerging Auto’s engagement of Sherpa and Sherpa’s efforts to monetize Emerging Auto’s patents,” which “falls squarely within the Court’s order denying Toyota’s motion to compel.” (Id.) Toyota responds that the Court’s order denying its motion to compel does not prohibit the testimony its subpoena seeks. (Dkt. No. 154 at 2-3.) Toyota argues it is not seeking negotiations regarding unconsummated license agreements but, instead, “seeks discovery to do with the extensive pre-litigation work Sherpa conducted for EA.” (Id.) Specifically, Toyota asserts that it seeks testimony regarding (1) “mappings of EA’s asserted patents against Toyota’s and others’ products (i.e., the ‘Evidence of Use’ charts)”; (2) “valuations of EA’s patent portfolio”; (3) “communications between EA and Sherpa”; and (4) “and at least the identities of and information

shared with the parties Sherpa solicited to buy EA’s patent portfolio.” (Id.) Toyota contends that this testimony is relevant to at least non-infringement and damages. (Id. at 4-5.) The Court finds that some, but not all, of the testimony Toyota seeks is discoverable. While the Court denied Toyota’s motion to compel EA’s negotiations for unconsummated licenses, that is not a blanket preclusion into EA’s monetization efforts. The Court will now address the four topics of testimony that Toyota seeks. 1. Evidence of Use Charts (Topic Nos. 7-8) Toyota seeks testimony regarding the Evidence of Use charts Sherpa created related to the asserted patents. (Dkt. No. 154 at 2-3.) Toyota seeks all Evidence of Use charts against Toyota’s and others’ products. (Id.) The Court finds that testimony regarding Evidence of Use charts Sherpa created against

Toyota products is discoverable. If Sherpa created Evidence of Use charts mapping the asserted claims against Toyota products, those charts would be relevant to the claims and defenses in this case, including non-infringement. Evidence of Use charts mapping the asserted claims against Toyota products is unrelated to negotiations regarding unconsummated license agreements. However, the Court finds that testimony regarding Evidence of Use charts Sherpa created for non- Toyota products is not discoverable. If Sherpa created Evidence of Use charts for non-Toyota products, it is reasonable to assume that Sherpa used these in its solicitations with third parties to license EA’s patent portfolio. Toyota’s request for Sherpa’s Evidence of Use charts for non-Toyota products appears to be an improper backdoor attempt at obtaining information that the Court has already held is undiscoverable. Based on a review of Toyota’s deposition subpoena, Topics 7 and 8 encompass Toyota’s request for testimony regarding Evidence of Use charts. (Dkt. No.

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Emerging Automotive LLC v. Kia Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emerging-automotive-llc-v-kia-corporation-txed-2025.