Rubicon Research Private Limited v. Kartha Pharmaceuticals Inc.

CourtDistrict Court, W.D. North Carolina
DecidedJanuary 28, 2022
Docket3:21-cv-00129
StatusUnknown

This text of Rubicon Research Private Limited v. Kartha Pharmaceuticals Inc. (Rubicon Research Private Limited v. Kartha Pharmaceuticals Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rubicon Research Private Limited v. Kartha Pharmaceuticals Inc., (W.D.N.C. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:21-cv-129-MOC-DSK

RUBICON RESEARCH PRIVATE LIMITED, Plaintiff,

ZAKLADY FARMACEUTYCZNE POLPHARMA S.A., Consolidated Plaintiff, ORDER

v.

KARTHA PHARMACEUTICALS INC., et al., Defendants.

THIS MATTER is before the Court on Plaintiff’s Motion to Dismiss, pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure. (Doc. No. 99). I. BACKGROUND In this action, filed on March 30, 2021, Plaintiff Rubicon Research Private Limited alleged that Defendants Kartha Pharmaceuticals and Manoj Mazhuvancheril stole Rubicon’s trade secrets for manufacturing Plaintiff’s 5 mg baclofen drug and that Kartha is planning to sell its own baclofen. Rubicon brings claims against Defendants under the federal Defend Trade Secrets Act of 2016, North Carolina Trade Secrets Protection Act, and the North Carolina’s Unfair and Deceptive Trade Practices Act, as well as North Carolina common law claims for unfair competition, breach of fiduciary duty, and unjust enrichment. This action has been consolidated with Zaklady Farmaceutyczne Polpharma S.A. v. Kartha Pharmacuticals, Inc., Civ. No. 3:21cv129, in which the plaintiff Polpharma in that case claims that Kartha violated conflict of interest and confidentiality provisions in a consulting agreement between the parties in that 1 case. The parties have engaged in substantial discovery, with discovery due to close on February 15, 2022, with dispositive motions due on March 2, 2022, and with a trial date set for June 20, 2022. Plaintiff filed the pending motion to dismiss on December 23, 2021. In support of the motion to dismiss, Plaintiff asserts that while it has a strong case on liability against Defendants,

circumstances have changed significantly since filing this lawsuit that make it appropriate for Plaintiff to voluntarily dismiss its claims. According to Plaintiff, it is uncertain whether Defendants will launch their baclofen product. Plaintiff further asserts that there are now multiple additional competing products in the market. Plaintiff contends that there may no longer be value in pursuing Defendants for their wrongful conduct since prices have eroded by over 75% for the 5 mg baclofen tablet. Finally, Plaintiff contends that there will be no prejudice to Defendants if the case is dismissed without prejudice. Plaintiff asserts that the discovery conducted in this case will be used in arbitration in the lawsuit between Defendants and Polpharma and could be used in a subsequent action if circumstances change again.

In their response to the motion to dismiss, Defendants do not oppose dismissal of this action, but they object to the conditions of dismissal. Defendants ask the court to dismiss the case with prejudice with leave to Defendants to take four depositions from Plaintiff to allow Defendants to establish Plaintiff’s bad faith in filing this case, and with leave to Defendants to file a motion for costs and attorney fees. Alternatively, Defendants ask for this Court to dismiss the case without prejudice, but on the condition that Plaintiff must pay Defendants’ costs and attorney fees. II. DISCUSSION Pursuant to Fed. R. Civ. P. 41(a)(2), once a defendant has served an answer or a motion 2 for summary judgment, and absent the consent of all parties, “an action may be dismissed at the plaintiff's request only by court order, on terms that the court considers proper.” FED. R. CIV. P. 41(a)(2). The purpose of the rule “is freely to allow voluntary dismissals unless the parties will be unfairly prejudiced.” Davis v. USX Corp., 819 F.2d 1270, 1273 (4th Cir. 1987); see also Lang v. Manufacturers & Traders Tr. Co., 274 F.R.D. 175, 182 (D. Md. 2011). Accordingly, “[a]

plaintiff's motion to voluntarily dismiss a claim [without prejudice] should not be denied absent plain legal prejudice to the defendant.” Ellett Bros., Inc. v. U.S. Fid. & Guar. Co., 275 F.3d 384, 388 (4th Cir. 2001). To avoid unfair prejudice, the district court is permitted “to impose conditions on voluntary dismissal to obviate any prejudice to the defendants which may otherwise result from the dismissal without prejudice. In considering a motion for voluntary dismissal, the district court must focus primarily on protecting the interests of the defendant.” Davis, 819 F.2d at 1273 (citations omitted). In assessing the degree of prejudice that might be caused by a Rule 41(a)(2) dismissal,

the Court applies a “non-exclusive, multi-factor test,” including such factors as “(1) the opposing party’s effort and expense in preparing for trial; (2) excessive delay or lack of diligence on the part of the movant; (3) insufficient explanation of the need for a dismissal; and (4) the present stage of litigation.” Wilson v. Eli Lilly & Co., 222 F.R.D. 99, 100 (D. Md. 2004) (citations omitted); see also Lang, 274 F.R.D. at 182. “‘[I]t is well established that, for purposes of Rule 41(a)(2), prejudice to the defendant does not result from the prospect of a second lawsuit’ or ‘the possibility that the plaintiff will gain a tactical advantage over the defendant in future litigation.’” Howard v. Inova Health Care Servs., 302 F. App’x 166, 179 (4th Cir. 2008) (citing Davis, 819 F.2d at 1274–75). 3 After applying the four relevant factors, the Court finds that dismissing this action will not unfairly prejudice Defendants. Moreover, the Court declines to grant Defendants’ alternative requested conditions of dismissal. As to the first factor—Defendant’s effort and expense in preparing for trial—Plaintiff contends that there is no prejudice to Defendants as to the effort and expense in preparing for

trial because dismissal at this point will save Defendants the costs of further preparation for trial, including the upcoming costs of having to take and defend depositions and finalize expert reports. Plaintiff contends that, in addition, the written discovery that has been exchanged may be used in a refiled action. Crocker v. Brown, No. 1:16-CV-00005-MR-DLH, 2016 WL 7404719, at *2 (W.D.N.C. Dec. 21, 2016). Defendants do not present any opposition on this point except to state that Plaintiff is unlikely to refile the case given its stated reasons for dismissing now. Plaintiff asserts, however, that it may refile the litigation if circumstances change again. The Court finds that this factor weighs in favor of granting Plaintiff’s motion to dismiss.

As to the second factor—excessive delay or lack of diligence on the part of the movant— the Court is satisfied that Plaintiff exercised diligence in pursuing its claims and not delay, conducting expedited discovery efficiently and effectively. Defendant does not challenge this factor. The Court finds that this factor weighs in favor of granting Plaintiff’s motion to dismiss. As to the third factor—insufficient explanation of the need for a dismissal—Plaintiff has explained that Rubicon pioneered its baclofen product (receiving approval for it in 2017) and enjoyed a years-long competitive advantage, demonstrating the value of the product and the information concerning the product that is at issue in this case. Plaintiff notes that when it filed this action Defendants had received the third market approval for this product. There were three 4 approvals then, and now there are seven companies with approval. Plaintiff asserts that it did not know when it filed this action in March 2021 that ten months later market would be flooded with companies with approval to sell the 5 mg baclofen market. The Court finds that this is a sufficient explanation for Plaintiff to take voluntary dismissal now.

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Related

Nannette B. Davis v. Usx Corporation
819 F.2d 1270 (Fourth Circuit, 1987)
Howard v. INOVA Health Care Services
302 F. App'x 166 (Fourth Circuit, 2008)
Wilson v. Lilly
222 F.R.D. 99 (D. Maryland, 2004)
Lang v. Manufacturers & Traders Trust Co.
274 F.R.D. 175 (D. Maryland, 2011)

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Bluebook (online)
Rubicon Research Private Limited v. Kartha Pharmaceuticals Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rubicon-research-private-limited-v-kartha-pharmaceuticals-inc-ncwd-2022.