Reald Spark, LLC v. Microsoft Corporation

District Court, W.D. Washington·Decided October 27, 2023·No. 2:22-cv-00942·Unknown

Opinion

1 2 3 4

5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 REALD SPARK, LLC, CASE NO. 2:22-cv-00942-TL 12 Plaintiff, ORDER ON MOTION TO AMEND v. 13 MICROSOFT CORPORATION, 14 Defendant. 15

16 17 This matter is before the Court on Defendant Microsoft Corporation’s Motion for Leave 18 to File Amended Affirmative Defense and Counterclaim. Dkt. Nos. 97, 98-2 (sealed). Having 19 reviewed Plaintiff RealD Spark, LLC’s response (Dkt. No. 103), Defendant’s reply (Dkt. 20 Nos. 106, 107 (sealed)), and the relevant record, the Court GRANTS the motion. 21 I. BACKGROUND 22 The background and procedural history of this matter was previously recounted in the 23 Court’s Order granting Defendant’s motion to compel discovery. See Dkt. No. 63 at 2–4. Since 24 that Order, the Court also denied Defendant’s motion for a stay pending inter partes review (see 1 Dkt. No. 86) and granted in part and denied in part Plaintiff’s own motion to compel discovery 2 (see Dkt. No. 101). In sum, Plaintiff alleges that Defendant has incorporated Plaintiff’s 3 technology (“the ‘985 patent”) into Defendant’s own products and brings claims of breach of 4 contract, violation of state and federal trade secrets statutes, and patent infringement. See Dkt.

5 Nos. 1 (complaint), 30 (Defendant’s answer and counterclaim), 32 (Plaintiff’s answer). 6 Defendant states that on September 1, 2023, it received discovery from Plaintiff 7 appearing to provide evidence that Daniil Kononenko and Victor Lemptisky, two researchers 8 affiliated with the Skolkovo Institute of Science and Technology (“Skoltech”) in Moscow, 9 “contributed to the conception and development of the subject matter claim by the ‘985 Patent.” 10 Dkt. No. 98-2 at 6. Specifically, Defendant provides emails that show a discussion between 11 Plaintiff and the researchers about adding them as inventors to the ‘985 patent, suggesting that 12 Plaintiff intentionally left them out. See Dkt. Nos. 98-7 (sealed), 98-8 (sealed), 98-9 (sealed). 13 Defendant brings the instant motion to amend its Answer “for the limited purpose of 14 adding an affirmative defense and counterclaim for declaratory relief that the Skoltech

15 researchers Daniil Kononenko and Victor Lempitsky should have been named inventors on the 16 ‘985 patent,” which could warrant invalidation or correction of the patent. Dkt. No. 98-2 at 5; 17 Dkt. No. 98-4 (sealed) (redlined version of proposed amendment); see also Dkt. No. 107 (sealed) 18 (reply). Plaintiff opposes. See Dkt. No. 103. 19 II. LEGAL STANDARD 20 Once a court has entered a scheduling order, the “good cause” standard of Federal Rule 21 of Civil Procedure 16(b)(4) initially governs a party’s ability to amend their pleading. Johnson v. 22 Mammoth Recreation, Inc., 975 F.2d 604, 607–08 (9th Cir. 1992) (affirming denial of a belated 23 motion to amend); see also Santillan v. USA Waste of Cal., Inc., 853 F.3d 1035, 1048 (9th Cir.

24 2017) (affirming denial of amendment where request to amend came eight months after the 1 deadline). “Good cause” looks to whether a scheduled deadline could not “reasonably be met 2 despite the diligence of the party seeking the extension.” Johnson, 975 F.2d at 609 (quoting the 3 Rule 16 advisory committee’s note to 1983 amendment); see also DRK Photo v. McGraw-Hill 4 Glob. Educ. Holdings, LLC, 870 F.3d 978, 989 (9th Cir. 2017) (describing diligence as “the

5 central inquiry” under Rule 16(b)(4)). 6 If the good cause standard is met, a party must then show that (1) the amendment is 7 proper and (2) that leave is appropriate. See Nat’l Prods. Inc. v. Akron Res., Inc., No. C15-1553, 8 2016 WL 9224046, at *4 (W.D. Wash. Nov. 8, 2016) (describing the “two hurdles” for 9 amendments under Rules 16(b) and 15(a)); Soaring Helmet Corp. v. Nanal, Inc., No. C09-789, 10 2011 WL 39058, at *4 (W.D. Wash. Jan. 3, 2011) (same). This standard is to be applied with 11 “extreme liberality,” Sonoma Cnty. Ass’n of Retired Emps. v. Sonoma Cnty., 708 F.3d 1109, 12 1117 (9th Cir. 2013) (citing Foman v. Davis, 371 U.S. 178, 182 (1962)), to facilitate the decision 13 of cases “on the merits rather than on the pleadings or technicalities.” DCD Programs, Ltd. v. 14 Leighton, 833 F.2d 183, 186 (9th Cir. 1987) (quoting United States v. Webb, 655 F.2d 977, 979

15 (9th Cir. 1981)); see also Fed R. Civ. P. 15(a)(2) (“The court should freely give leave when 16 justice so requires.”). 17 Courts in this Circuit consider five factors to assess whether to grant leave to amend 18 under Rule 15(a): “(1) bad faith, (2) undue delay, (3) prejudice to the opposing party, (4) futility 19 of amendment, and (5) whether plaintiff has previously amended his complaint.” In re W. States 20 Wholesale Nat. Gas Antitrust Litig., 715 F.3d 716, 738 (9th Cir. 2013) (quoting Allen v. City of 21 Beverly Hills, 911 F.2d 367, 373 (9th Cir. 1990)) (“the Allen factors”), aff’d sub nom. Oneok, 22 Inc. v. Learjet, Inc., 575 U.S. 373 (2015). “Prejudice is the ‘touchstone of the inquiry under Rule 23 15(a).’” Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003) (quoting

24 Lone Star Ladies Inv. Club v. Schlotzky’s Inc., 238 F.3d 363, 368 (5th Cir. 2001)); see also 1 William Inglis & Sons Baking Co. v. ITT Cont’l Baking Co., Inc., 668 F.2d 1014, 1053 n.68 (9th 2 Cir. 1982) (“[T]he most important [factor] is whether amendment would result in undue 3 prejudice to the opposing party . . . .” (citing Howey v. United States, 481 F.2d 1187, 1190 (9th 4 Cir. 1973)). “The party opposing amendment bears the burden of showing prejudice.” DCD

5 Programs, 833 F.2d at 187. 6 III. DISCUSSION 7 A. Good Cause Under Rule 16 8 Defendant argues that it satisfies the “good cause” standard of Rule 16 because it acted 9 diligently in seeking to amend its answer. See Dkt. No. 98-2 at 9–10. Plaintiff rests its opposition 10 almost entirely on Defendant’s failure to meet this standard. See Dkt. No. 103 at 5–10. The crux 11 of Plaintiff’s response is that Defendant was aware of inventorship issues as early as January 12 2023 and could have investigated (and amended their answer) before now. See id. at 5. 13 Defendant replies that while it had suspicions about the origins of the patent’s subject matter, 14 evidence of an inventorship defense only recently came to light. See Dkt. No. 107 at 4–7.

15 Here, the Court finds that Defendant has met the “good cause” standard of Rule 16. 16 Diligence is “the central inquiry,” DRK Photo, 870 F.3d at 989, and Defendant acted diligently 17 in seeking amendment.

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

Reald Spark, LLC v. Microsoft Corporation, (W.D. Wash. 2023).

Reald Spark, LLC v. Microsoft Corporation (Reald Spark, LLC v. Microsoft Corporation) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related