Medcenter Holdings Inc v. Web MD Health Corp.

CourtDistrict Court, S.D. New York
DecidedMarch 31, 2025
Docket1:20-cv-00053
StatusUnknown

This text of Medcenter Holdings Inc v. Web MD Health Corp. (Medcenter Holdings Inc v. Web MD Health Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Medcenter Holdings Inc v. Web MD Health Corp., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- x MEDCENTER HOLDINGS INC., : MEDCENTER SOLUTIONS SA, MED : SOLUTIONS MÉXICO, S. DE R.L. DE C.V. : AND MEDCENTER SOLUTIONS DO : 20-cv-00053 (ALC) (GWG) BRASIL SA, : : ORDER & OPINION Plaintiffs, : : -against- : x WEBMD HEALTH CORP., MEDSCAPE, LLC, and WEBMD GLOBAL LLC, Defendants. --------------------------------------------------------------------- ANDREW L. CARTER, JR., District Judge: Plaintiffs Medcenter Holdings Inc. (“Medcenter Holdings”), Medcenter Solutions SA (“Medcenter Argentina”), Med Solutions Mexico, S. de R.L. de C.V. (“Medcenter Mexico”), and Medcenter Solutions do Brasil SA, (collectively “Medcenter” or “Plaintiffs”) bring this action against Defendants WebMD Health Corp. (“WebMD”), Medscape, LLC (“Medscape”), and WebMD Global LLC (“WebMD Global”) (collectively “WebMD” or “Defendants”) for misappropriation of trade secrets under the Defend Trade Secrets Act (“DTSA”), 18 U.S.C. § 1836 et seq. and New York state common law; and against Defendant WebMD for breach of contract. ECF No. 18. Plaintiffs allege that (i) WebMD Defendants’ willfully and surreptitiously planned theft, misappropriation and use of Medcenter’s trade secrets and confidential information, which comprised the heart of Medcenter’s business throughout Latin America, resulting in the destruction of Medcenter’s entire business; and (ii) WebMD Health Corp. breached a 2014 non- disclosure agreement (“NDA”) entered into between Medcenter Holdings and Defendant WebMD Health Corp. in connection with WebMD Health Corp. conducting extensive due diligence for its potential acquisition of Medcenter’s entire Latin American business that enabled the WebMD Defendants to selectively identify and poach some of the most important senior management employees and officers of Medcenter as part of the WebMD Defendants’ collective scheme to steal Medcenter’s entire Latin American business. Id. at ¶ 1. Plaintiffs further allege that in or about the spring of 2016, the Defendants orchestrated a scheme to steal Medcenter’s

core trade secrets after the Defendants enlisted, in secret, the active participation of Medcenter Argentina’s Director and Vice President of Sales and Key Accounts, Mariel Aristu. Id. at ¶ 3. Defendants submitted a motion for summary judgment pursuant to Federal Rule of Civil Procedure 56 seeking to dismiss the First Amended Complaint (“FAC”). ECF No. 132. Plaintiffs oppose this motion. ECF No. 147. For the reasons set forth below, Defendants’ motion for summary judgment is GRANTED in part and DENIED in part. STATEMENT OF FACTS The Court assumes the Parties’ familiarity with the facts, which are set forth more fully in the FAC. ECF No. 18. Plaintiff Medcenter became the dominant provider of medical and

pharmaceutical drug information, professional accreditation and continuing education to physicians in Central and South America. Id. at ¶ 28. To support its business, Medcenter developed and maintained two extensive databases – the “Physicians Database” and the “Salesforce Database.” Id. at ¶¶ 31-48. Medcenter had developed the “Physicians Database” – a large, highly detailed proprietary database of physicians throughout Latin America, including dentists and their areas of practice and specialties, as well as medical students. Id. at ¶¶ 31. Medcenter maintained the Physicians Database in a Microsoft SQL database structure and updated and organized the data fields that included extensive non-public granular data on physicians. Id. ¶ 33. At its peak in early 2016, Medcenter possessed this granular data on about 420,000 medical professionals across at least 58 distinct medical specialties, which reflected “enormous value as a proprietary trade secret” to Medcenter. Id. at ¶ 40. As a result, Medcenter tightly restricted access to the Physicians Database, only allowing one Medcenter employee database manager named Carlos Padilla to have full access from 2014 to 2016 and some “senior community managers to have limited access rights.” Id. at ¶¶ 42-44. Not even the CEO of

Medcenter Holdings and Medcenter Argentina, Daniel Sanmarco (“Sanmarco”), had access rights to the Physicians Database. Id. The “Salesforce Database” was used to distribute invitations to medical professionals in the Physicians Database to participate in a program to deliver information about pharmaceutical products that pharmaceutical companies paid Medcenter to advertise. Id. at ¶¶ 45-48. As of mid- 2016, Medcenter’s primary revenue driver was engagements by Pharma Clients to create and execute these structured drug and medical product marketing programs called “Directed Projects” that targeted specific physicians by practice specialty throughout Latin America. Id. at ¶¶ 45-46. Medcenter’s most critical asset for contracting with Pharma Clients for Directed

Projects was its ability to access detailed information concerning Latin American physicians’ prescribing behavior and for Medcenter’s Pharma Clients to account for that information when developing and executing marketing activities, as well as Medcenter’s ability to deliver targeted Pharma Clients’ messages to physicians in the Physicians Database that may influence the physicians’ prescribing behavior. Id. at ¶ 51. After Medcenter disseminated information about a pharmaceutical product for a Directed Project to targeted physicians through the Salesforce Database, the physicians could respond to the marketing messages, which provided “useful data and feedback” to Medcenter. Id. at ¶ 54. “All this unique pharmaceutical drug and medical product project performance data was stored in Medcenter’s Salesforce Database, which was a secure hosted online platform.” Id. at ¶ 55. Only Sanmarco and Estefania Aristu, who was the Salesforce Database administrator for all of Medcenter starting in 2003 or 2004, had the access password keys to the Salesforce Database. Id. at ¶¶ 60-61. Plaintiffs allege that Defendants conspired together to poach Aristu in June 2016

and that before she left to work for Defendants, she stole “extensive amounts” of data from the Physicians Database and the Salesforce Database and provided this data to Defendants. Id. ¶¶ 3- 5. While Aristu did not have access to the Physicians Database, Plaintiffs allege that Aristu was able to “request information from the Physicians Database on an as-needed basis from other Medcenter senior community managers.” Id. at ¶ 71. Plaintiffs also allege that in May 2016, Sanmarco provided Aristu with the Salesforce Database access key before she attended a Miami conference and that she used this to “access, download, retain and steal substantial amounts of confidential Medcenter data on all ongoing Directed Projects that were in process as of June 2016.” Id. at ¶¶ 131-33. Medcenter revoked all

of Aristu’s “database access credentials” when it became aware of her departure from Medcenter in June 2016. Id. at ¶ 152. Medcenter further alleges that Aristu’s transfer of information from these databases to Defendants constituted a theft of trade secrets that quickly devastated Medcenter’s business, but that Medcenter only began to suspect this that Aristu had stolen this data in the fall of 2017 and had disclosed it to the Defendants as part of a conspiracy between her and the Defendants. Id. ¶¶ 6-9. During the first three quarters of 2017, Plaintiffs allege that Medcenter lost clients and that Defendants took over “at least nine Directed Projects, which Aristu personally had been in charge of at Medcenter” in October 2017. Id. at ¶ 168.

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Bluebook (online)
Medcenter Holdings Inc v. Web MD Health Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/medcenter-holdings-inc-v-web-md-health-corp-nysd-2025.