Life Spine, Inc. v. Aegis Spine, Inc.

District Court, N.D. Illinois·Decided November 16, 2023·No. 1:19-cv-07092·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

LIFE SPINE, INC., ) ) No. 19 CV 7092 Plaintiff, ) ) v. ) Magistrate Judge Young B. Kim ) AEGIS SPINE, INC., ) ) November 16, 2023 Defendant. )

MEMORANDUM OPINION and ORDER

Before the court are Plaintiff Life Spine, Inc.’s (“Life Spine”) and Defendant Aegis Spine, Inc.’s (“Aegis”) motions in limine No. 1. For the following reasons, Life Spine’s motion is granted in part and denied in part, and Aegis’s motion is denied: Background This is an action between two medical device companies that develop and market “expandable cage” spinal implants. (R. 494, Mem. Op. and Order at 2.) Life Spine alleges that Aegis stole confidential information and breached contractual obligations in order to develop AccelFix-XT (“AccelFix”), a medical device that directly competes with Life Spine’s ProLift Expandable Spacer System (“ProLift”). In defense, Aegis argues that ProLift is not innovative and does not contain trade secrets, and, in any event, Aegis’s parent company, L&K Biomed Co., Ltd. (“L&K”), independently developed AccelFix. The parties have filed various motions in limine in preparation for the January 16, 2024 jury trial in this case. (R. 542.) This order addresses each party’s motion in limine No. 1. (R. 554; R. 568.)

Legal Standard The court’s authority to rule on motions in limine springs from its inherent authority to manage trials. Luce v. United States, 469 U.S. 38, 41 n.4 (1984); Jenkins v. Chrysler Motors Corp., 316 F.3d 663, 664 (7th Cir. 2002). Through such motions, the court performs a “gatekeeping function . . . to eliminate from further consideration evidentiary submissions that clearly ought not to be presented to the

jury because they clearly would be inadmissible for any purpose.” Jonasson v. Lutheran Child & Family Servs., 115 F.3d 436, 440 (7th Cir. 1997). The moving party bears the burden of proving blanket inadmissibility. See Mason v. City of Chi., 631 F. Supp. 2d 1052, 1056 (N.D. Ill. 2009). Absent such a showing, evidentiary rulings should be deferred until trial, where decisions can be informed by the context, foundation, and relevance of the contested evidence within the framework of the trial as a whole. See Anglin v. Sears, Roebuck & Co., 139 F. Supp. 2d 914, 917 (N.D. Ill.

2001). “A pre-trial ruling denying a motion in limine does not automatically mean that all evidence contested in the motion will be admitted at trial.” Bruce v. City of Chi., No. 09 CV 4837, 2011 WL 3471074, at *1 (N.D. Ill. July 29, 2011). Rather, the court is free to revisit evidentiary rulings during trial as appropriate in the exercise of its discretion. Luce, 469 U.S. at 41-42. Analysis A. Aegis’s Motion No. 1 The motion is denied. Aegis seeks to bar Life Spine from arguing or

introducing evidence relating to an April 2019 recall of the spinal implant device “Opticage.” (R. 554, Def.’s Mot. No. 1 at 1.) Aegis argues that certain evidence regarding this third-party device is relevant to demonstrate that: (1) Opticage “contains design elements” that appear in ProLift, undercutting Life Spine’s contention that ProLift was “innovative or constitute[d] trade secrets”; and (2) its parent company, L&K, “independently developed the AccelFix products,” as

evidenced by the fact that U.S. Patent No. 8,105,382 (“the ’382 Patent”), which discloses Opticage’s design and components, appears in the AccelFix design history file. (Id.) Aegis draws a distinction, however, between the relevance of Opticage itself and the FDA’s April 2019 recall of Opticage devices. Aegis asserts the latter is not relevant here, and any attempt by Life Spine to bring the jury’s attention to the recall will only distract from the central issues in the case. (Id. at 2.) Aegis further contends

that “reference to the Opticage recall will naturally result in a trial within the trial,” resulting in judicial inefficiency and possible juror confusion. (Id.) Finally, Aegis represents that the timing of the AccelFix 510(k) FDA filing in March 2019 shows the irrelevance of the April 2019 Opticage recall because any misappropriation by Aegis would have had to occur before the AccelFix FDA submission. (Id. at 3.) Life Spine responds that Aegis cannot have it both ways—it cannot seek to keep in certain information about Opticage while excluding other probative evidence about the same device. (R. 583, Def.’s Resp. at 1.) Life Spine represents that Aegis’s

expert Brad Culbert is a named inventor of Opticage, who “is expected to testify extensively” about the Opticage device and prohibiting Life Spine from “put[ting] Aegis’s arguments and [] Culbert’s testimony in context” by pointing out that Opticage “was recalled not once but twice,” would prejudice Life Spine. (Id.) Life Spine explains that such recalls show “how difficult it is to develop an expandable spinal implant,” undermining Aegis’s claims that it developed AccelFix

products “quickly and independently” in less than a year, whereas Culbert testified it took nearly six years to develop Opticage—and the device “was permanently taken off the market in the wake of recalls.” (Id. at 2.) Life Spine argues it should be allowed to present this context to the jury to counter Aegis’s independent development claim. (Id. at 3.) Life Spine also argues the Opticage recalls are relevant to testing the credibility of Aegis’s witnesses who assert that because the AccelFix design history

file refers to the ’382 Patent, the jury may infer that L&K independently developed AccelFix. (Id.) But because Opticage was previously recalled in 2016, and then again in 2019, Life Spine argues the jury should be provided insight regarding Aegis’s claims that it developed its own products by drawing on a device that failed twice. (Id.) Life Spine further contends that the Opticage recalls support its claim that ProLift is innovative because it “has been on the market for years,” while Opticage was taken off the market after two recalls. (Id. at 4.) Finally, Life Spine points out the Opticage recalls “put into context” Culbert’s expertise “as the developer of an early expandable spinal cage,” and that the jury would be misled if Culbert were

painted as an innovator without “the full picture.” (Id.) The court agrees with Life Spine. If Aegis wants to introduce evidence about Opticage to show how it independently developed AccelFix products, then it cannot pick and choose which evidence about Opticage may be offered at trial. The jury may weigh Culbert’s or any other Aegis witness’s credibility when assessing such evidence, making the recalls an appropriate topic on cross examination. Tagatz v.

Marquette Univ., 861 F.2d 1040, 1042 (7th Cir. 1988). While the court does not intend to conduct a “trial within the trial” regarding the Opticage recalls, (R. 554, Def.’s Mot. No. 1 at 2), Aegis has not shown that evidence regarding the Opticage recalls is inadmissible for any purpose, see Townsend, 287 F. Supp. 2d at 872. By contrast, Life Spine has demonstrated the relevance of such evidence. For these reasons, if Aegis offers information about Opticage, the good, the bad, and the ugly pertaining to Opticage are fair game at trial.

B. Life Spine’s Motion No. 1 The motion is granted in part and denied in part.

Free access — add to your briefcase to read the full text and ask questions with AI

Life Spine, Inc. v. Aegis Spine, Inc., (N.D. Ill. 2023).

Life Spine, Inc. v. Aegis Spine, Inc. (Life Spine, Inc. v. Aegis Spine, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related