HCL Technologies Limited v. Atos SE

CourtDistrict Court, N.D. Texas
DecidedMarch 12, 2024
Docket3:23-cv-00868
StatusUnknown

This text of HCL Technologies Limited v. Atos SE (HCL Technologies Limited v. Atos SE) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HCL Technologies Limited v. Atos SE, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

HCL TECHNOLOGIES LIMITED, § and HCL AMERICA, INC., § § Plaintiffs, § § v. § Civil Action No. 3:23-cv-868-L § ATOS S.E.; ATOS IT SOLUTIONS AND § SERVICES, INC.; ATOS IT § OUTSOURCING SERVICES, LLC; § ATOS GOVERNMENTAL IT § OUTSOURCING SERVICES, LLC; § ATOS HEALTHCARE SERVICES, § LLC; ATOS DIGITAL HEALTH § SOLUTIONS, INC.; CNA FINANCIAL § CORPORATION; and CONTINENTAL § CASUALTY COMPANY, § § Defendants. §

ORDER

The Findings, Conclusions and Recommendation of the United States Magistrate Judge David Horan (“Report”) (Doc. 38) was entered on January 31, 2024, recommending that the court grant in part and deny in part Defendants Atos SE.; Atos IT Solutions and Services, Inc.; Atos IT Outsourcing Services, LLC; ATOS Governmental IT Outsourcing Services, LLC; Atos Healthcare Services, LLC; and Atos Digital Health Solutions, Inc., (the “Atos Defendants”); CNA Financial Corporation; and Continental Casualty Company’s (the “CNA Defendants”) (collectively, “Defendants”) Motion to Dismiss (“Motion”) (Doc. 19). On February 14, 2024, Plaintiffs HCL Technologies Limited and HCL America, Inc. (collectively, “Plaintiffs”) filed Objections to the Report (“Plaintiffs’ Objections”) (Doc. 39), and Defendants’ filed Objections to the Report (“Defendants’ Objections”) (Doc. 40). On February 27, 2024, Plaintiffs filed a Response to Defendants’ Objections (“Plaintiffs’ Response”) (Doc. 41), and, on February 28, 2024, Defendants filed a Response to Plaintiffs’ Objections (“Defendants’ Objections”) (Doc. 42). On March 11, 2024, Plaintiffs filed a Reply (Doc. 43) to Defendants’ Response (Doc. 42) (“Plaintiffs’ Reply”), and on March 12, 2024, Defendants filed a Reply (Doc. 44) to Plaintiffs’

Response (Doc. 41) (“Defendants’ Reply”). The court strikes Plaintiffs’ Reply and Defendants’ Reply because they were filed without leave of court, and the court did not direct the parties to file reply briefs. See Doc. 21 at 2 (“The court does not allow parties to file a reply brief with respect to magistrate judge orders or findings and recommendations, unless leave is granted to file the reply brief. The court will strike or disregard any reply brief filed in violation of this order.”). Moreover, the court has reviewed Plaintiffs’ Reply and Defendants’ Reply and determines that the arguments set forth do not change its decision. I. Discussion On April 24, 2023, Plaintiffs filed their Complaint (Doc. 1) against Defendants, alleging

direct copyright infringement under 17 U.S.C. § 101 et seq., equitable accounting, unjust enrichment, and common law unfair competition. Doc. 38 at 2-3. Plaintiffs also brought claims against the Atos Defendants for contributory copyright infringement, vicarious copyright infringement, and inducement of copyright infringement under 17 U.S.C. § 101 et seq. Id. at 2. Plaintiffs seek a variety of remedies, including declaratory judgments, a preliminary and permanent injunction under 17 U.S.C. § 502, and money damages. Id. at 3. In Defendants’ Motion they argue that: (1) Plaintiffs engaged in “group pleading” and fail to allege facts with specificity regarding each of the Atos Defendants; Doc. 19 at 3-4; (2) Plaintiffs’ equitable accounting claim should be dismissed as both a cause of action and a remedy because “the facts and accounts at issue are so complex that adequate relief cannot be obtained at law, through discovery or otherwise;” id. at 5; (3) Plaintiffs’ unjust enrichment claim is preempted because it protects equivalent rights as the Copyright, id. at 8; and (4) Plaintiffs’ unfair competition claim should be construed as a claim for unfair competition by misappropriation that is preempted by the Copyright Act, id. at 7.

After determining that Defendants’ Motion should not be converted into a motion for summary judgment pursuant to Federal Rule of Civil Procedure 12(d) and on which matters the court can take judicial notice, the Report concluded that the court should dismiss with prejudice Plaintiffs’ unfair competition claim against Defendants, and unjust enrichment claim against the CNA Defendants only. Doc. 38 at 20. In Plaintiffs’ Objections, they argue that their unfair competition claim against the Atos Defendants is not preempted by the Copyright Act because they alleged “wrongdoing that is separate and apart from unauthorized copying and reproduction of copyrighted works.” Doc. 39 at 5. In Defendants’ Response, they argue that the Report’s conclusion is correct because the unfair

competition claim is preempted as a matter of law, because Section 301 of the Copyright Act preempts state law claims that fall within the general scope of federal copyright law. Doc. 42 at 3- 4. Under the Copyright Act and pursuant to Fifth Circuit precedent, courts apply a two-part test to determine whether an alleged state law claim is preempted. See Digital Drilling Data Sys., L.L.C. v. Petrolink Servs., Inc., 965 F.3d 365, 378 (5th Cir. 2020); 17 U.S.C. § 102-06. First, we examine the state claim to determine whether it falls within the subject matter of copyright as defined by 17 U.S.C. § 102. If so, we then consider the state cause of action to determine if it protects rights that are equivalent to any of the exclusive rights of a federal copyright, as defined in 17 U.S.C. § 106.

Digital Drilling Data Sys., L.L.C., 965 F.3d at 378 (citations and quotations omitted). As to the first prong, the Report correctly concluded that “computer software is a tangible medium protected by the Copyright Act.” Doc. 38 at 16 (citing Spear Mktg., Inc. v. BancorpSouth Bank, 791 F.3d 586, 597 (5th Cir. 2015)). As to the second prong, Plaintiffs argue that because the first prong fails the court need not reach the second prong. Doc. 39 at 8 n.3. The court disagrees, and finds that because Plaintiffs do not plead any additional elements that are not encompassed by the cause of

action for unfair competition by misappropriation, the second prong is also satisfied. Ultraflo Corp. v. Pelican Tank Parts, Inc., 845 F.3d 652, 657 (5th Cir. 2017) (explaining that “Texas’s unfair competition by misappropriation cause of action does not afford protection materially different from federal copyright law” (internal citations omitted)). Therefore, the court affirms the findings in the Report. Doc. 39 at 19 (finding that “[b]ecause the unfair competition claim … is unfair competition by misappropriation, this claim is preempted by the Copyright Act and must be dismissed) (citation omitted). Accordingly, the court overrules Plaintiffs’ objection. In Defendants’ Objections, they argue that the magistrate judge erred because the Atos Defendants do not have a business relationship with Plaintiffs; thus, Plaintiffs’ unjust enrichment

claim does not include the additional element of undue advantage and is, therefore, preempted against all Defendants, not just the CNA Defendants. Doc. 40.

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HCL Technologies Limited v. Atos SE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hcl-technologies-limited-v-atos-se-txnd-2024.