Monolithic Power Systems, Inc. v. Dong

CourtDistrict Court, N.D. California
DecidedJanuary 20, 2023
Docket4:20-cv-06752
StatusUnknown

This text of Monolithic Power Systems, Inc. v. Dong (Monolithic Power Systems, Inc. v. Dong) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Monolithic Power Systems, Inc. v. Dong, (N.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 MONOLITHIC POWER SYSTEMS, INC., Case No. 20-cv-06752-JSW (LB)

12 Plaintiff, DISCOVERY ORDER 13 v. Re: ECF Nos. 132, 134, 136, 142

14 WEI DONG, et al., 15 Defendants. 16 MONOLITHIC POWER SYSTEMS, INC., Case No. 22-cv-01986-JSW (LB) 17 (consolidated) Plaintiff, 18 v. 19 MERAKI INTEGRATED CIRCUIT 20 (SHENZEN) TECHNOLOGY, INC, 21 Defendants.

22 INTRODUCTION 23 Monolithic Power sued two former Monolithic employees (Lin Sheng and Wei Dong) and their 24 new company, Meraki. The former employees allegedly took Monolithic’s confidential information 25 and used it to obtain patents, create semiconductor products, and found Meraki, which is located in 26 China and competes with Monolithic. The remaining claim against the former employees is breach 27 of their employment contracts based on the misappropriation of confidential information. The 1 claims against Meraki are patent infringement, theft of trade secrets, tortious interference, and 2 unfair competition.1 The parties have four discovery disputes: (1) whether Meraki must respond to 3 interrogatories 6–9 and whether the former employees must supplement their responses to 4 interrogatories 15 and 17; (2) whether the defendants can depose Monolithic’s CEO Michael Hsing 5 about his hiring of Ms. Sheng and his alleged pressuring of her to disclose her former employer’s 6 confidential and trade-secret information; (3) whether the defendants can depose Monolithic’s 7 General Counsel Saria Tseng about the business circumstances surrounding Ms. Sheng’s departure; 8 and (4) the location of the former employees’ depositions.2 9 Meraki must respond to the contention interrogatories: they are not premature. The former 10 employees must amend their responses to interrogatories about what happened to Monolithic’s 11 information. If there is a fact record (presumably through Ms. Sheng’s deposition) that supports the 12 allegations about Mr. Hsing’s pressuring her to reveal confidential information, then the defendants 13 may depose him on this topic at the end of discovery. The deposition of the attorney is denied: it is 14 not crucial to the defendants’ case. The in-person location for the depositions of the former 15 employees is in Macau or Hong Kong. 16 ANALYSIS 17 1. Interrogatories (Letter Brief – ECF No. 132) 18 The issues are whether Meraki must respond to interrogatories 6–9 (or whether they are 19 premature contention interrogatories) and whether the former employees must supplement their 20 responses to two interrogatories. The defendants must respond to the interrogatories. 21 First, Meraki does not resist interrogatories 6–9 on any ground other than they are premature 22 contention interrogatories.3 Contention interrogatories are governed primarily by Rule 33(a)(2): 23 An interrogatory may relate to any matter that may be inquired into under Rule 26(b). An interrogatory is not objectionable merely because it asks for an opinion 24

25 1 Order – ECF No. 37 at 1–2 (summarizing case); First Am. Compl. – ECF No. 39 at 2 (¶¶ 2–3), 16–18 (¶¶ 62–68, 71–72); Third Am. Compl., No. 22-cv-01986-JSW (LB) – ECF No. 96. Citations are to Case 26 No. 20-cv-06752-JSW (LB) unless otherwise noted and refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 27 2 Disc Letter Brs. – ECF Nos. 132, 134, 136, 142. or contention that relates to fact or the application of law to fact, but the court may 1 order that the interrogatory need not be answered until designated discovery is 2 complete, or until a pretrial conference or some other time. 3 Fed. R. Civ. P. 33(a)(2). 4 “Courts using their Rule 33(a)(2) discretion generally disfavor contention interrogatories asked 5 before discovery is undertaken.” In re eBay Seller Antitrust Litig., No. C07-1882 JF (RS), 2008 6 WL 5212170, at *1 (N.D. Cal. Dec. 11, 2008). “In fact, courts tend to deny contention 7 interrogatories filed before substantial discovery has taken place, but grant them if discovery 8 almost is complete.” Id. Thus, as a general rule, a party moving to compel responses to contention 9 interrogatories at an early stage in litigation must show that the responses would “contribute 10 meaningfully” to one of the following: (1) clarifying the issues in the case; (2) narrowing the 11 scope of the dispute; (3) setting up early settlement discussion; or (4) exposing a substantial basis 12 for a motion under Rule 11 or Rule 56. In re Convergent Techs. Secs. Litig., 108 F.R.D. 328, 338– 13 39 (N.D. Cal. 1985); Nitride Semiconductors Co. v. Rayvio Corp., No. 17-cv-2952-EJD (SJK), 14 2017 LEXIS 206011, at *4 (N.D. Cal. Dec. 14, 2017). “These guidelines are not to be applied 15 rigidly, and so any decision must be made on a case by case basis.” HTC Corp. v. Tech. Props. 16 Ltd., No. C 08-00882 JF (HRL), 2011 WL 97787, at *2 (N.D. Cal. Jan. 12, 2011); see In re eBay 17 Seller, 2008 WL 5212170, at *1 & n.3 (acknowledging “non-rigid rule”). The requesting party has 18 the “burden of justification” to overcome the “general policy [] to defer propounding and 19 answering contention interrogatories until near the end of the discovery period.” In re Convergent 20 Techs., 108 F.R.D. at 336. 21 Fact discovery closes on March 3, 2023.4 Claim construction was a year ago. Monolithic served 22 amended infringement contentions four months ago.5 The parties have a settlement conference on 23 February 9, 2023.6 The interrogatories ask for Meraki’s contentions regarding non-infringement and 24 unenforceability of patents and trade-secrets. Interrogatory 9 asks only for information about 25 26 4 Order – ECF No. 141. 27 5 Disc. Letter Br. – ECF No. 132 at 3. 1 Meraki’s design-around efforts. The interrogatories are not premature, at least when one considers 2 the timeline of the case. That said, the parties’ scheduling of depositions during the last month of 3 discovery complicates that conclusion, at least somewhat. The defendants are not wrong that their 4 contention interrogatories are more appropriately staged after the Monolithic depositions. On the 5 other hand, the parties have to live with the case schedule. The best that the court can do is to order 6 the parties to schedule Monolithic depositions first, then provide a week’s time to respond to 7 contention interrogatories, and then schedule the Meraki depositions. The court can do no better 8 than that given that the parties are scheduling everything in February. The defendants may amend 9 their contention interrogatories one week after expert disclosures. 10 Second, the parties dispute the adequacy of the former employees’ responses to interrogatories 11 15 (Ms. Sheng) and 17 (Mr. Dong). Monolithic’s forensic examination of their Monolithic laptops 12 showed they had 220 Monolithic files. In their discovery responses on September 30, 2022, the 13 former employees admitted that they had forty of these files. Monolithic since identified seventy- 14 five more files.

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