Salhotra v. Simpson Strong-Tie Company, Inc.

CourtDistrict Court, N.D. California
DecidedMarch 3, 2022
Docket3:19-cv-07901
StatusUnknown

This text of Salhotra v. Simpson Strong-Tie Company, Inc. (Salhotra v. Simpson Strong-Tie Company, Inc.) 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
Salhotra v. Simpson Strong-Tie Company, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RAVI SALHOTRA, et al., Case No. 19-cv-07901-TSH

8 Plaintiffs, ORDER DENYING MOTION FOR 9 v. CLASS CERTIFICATION; GRANTING DEFENDANTS’ REQUEST FOR 10 SIMPSON STRONG-TIE COMPANY, JUDICIAL NOTICE; DENYING INC., et al., DEFENDANTS’ OBJECTIONS TO 11 PLAINTIFFS’ NON-EXPERT Defendants. DECLARATIONS; GRANTING 12 DEFENDANTS’ MOTION TO EXCLUDE EXPERT TESTIMONY; 13 DENYING AS MOOT PLAINTIFFS’ MOTION TO STRIKE DEFENDANTS’ 14 OBJECTIONS, DEFENDANTS’ MOTION TO STRIKE REPLY 15 EVIDENCE, AND DEFENDANTS’ OBJECTIONS TO NEW REPLY 16 EVIDENCE; AND GRANTING IN PART AND DENYING IN PART 17 MOTIONS TO SEAL 18 Re: Dkt. Nos. 132, 133, 134, 144, 145, 146, 19 150, 157, 163, 164, 168

20 21 I. INTRODUCTION 22 Plaintiffs brought this putative class action alleging that Defendants’ construction 23 connectors and fasteners prematurely corrode, causing danger to Plaintiffs’ properties and 24 requiring costly repairs. Pending before the Court are Plaintiffs’ Motion for Class Certification 25 (ECF No. 133), Defendants’ Request for Judicial Notice (ECF No. 144), Defendants’ Objections 26 to Plaintiffs’ Non-Expert Declarations (ECF No. 145), Defendants’ Motion to Exclude Expert 27 Testimony (ECF No. 146), Plaintiffs’ Motion to Strike Defendants’ Objections to Non-Expert 1 163), Defendants’ Motion to Strike New Reply Evidence (ECF. No. 164), and Administrative 2 Motions to Seal (ECF Nos. 132, 134, 150, and 168). 3 Having considered the parties’ positions, relevant legal authority, and oral argument, the 4 Court DENIES Plaintiffs’ Motion for Class Certification, GRANTS Defendants’ Request for 5 Judicial Notice, DENIES Defendants’ Objections to Plaintiffs’ Non-Expert Declarations, 6 GRANTS Defendants’ Motion to Exclude Expert Testimony, DENIES AS MOOT Plaintiffs’ 7 Motion to Strike Defendants’ Objections to Non-Expert Declarations, DENIES AS MOOT 8 Defendants’ Objections to Reply Evidence, DENIES AS MOOT Defendants’ Motion to Strike 9 New Reply Evidence, and GRANTS IN PART and DENIES IN PART the parties’ 10 Administrative Motions to Seal for the following reasons.1 11 II. BACKGROUND 12 A. Factual Background 13 This case concerns HD Strap-tie Holdowns and MAS Mudsil Anchors (collectively, 14 “Products”) created, marketed, and sold by defendants Simpson Strong-Tie Company and 15 Simpson Manufacturing Company Inc. (collectively “Simpson”). SAC ¶¶ 18-19, 24, 26, 31, 33, 16 38, 40, 45, 47, 53. The Products are embedded in homes’ concrete foundations, nailed to 17 structural members, and covered with house wrap or exterior cladding. Id. ¶¶ 19(a)-(b), 25, 32, 18 39, 46, 52. The Products are made of steel and coated with a standard “Low” G90 galvanization, a 19 thin layer of zinc, designed to protect the Products from corrosion. Id. ¶ 74. Between 1992 and 20 2018, Simpson sold more than 426 million Products. Id. ¶ 76. 21 Simpson advertises its Products to construction professionals in Simpson’s Wood 22 Construction Connector Catalogs (the “Catalogs”). Id. ¶ 62. Simpson’s Catalogs provide 23 corrosion information, recommendations, specifications, and warranties that broadly apply to all of 24 Simpson’s connectors. Id. ¶ 63. From 2005 to 2018, Simpson advertised the Products’ G90 25 galvanization was sufficient to protect the Products from corrosion. Id. ¶ 86. Simpson’s express 26 warranty for the Products states: 27 1 Simpson Strong-Tie connectors are designed to enable structures to resist the movement, stress, and loading that results from impact 2 events such as earthquakes and high velocity winds. Other Simpson Strong-Tie products are designed to the load capacities and uses listed 3 in this catalog. Properly-installed Simpson Strong-Tie Products will perform in accordance with the specifications set forth in the 4 applicable Simpson catalog. Additional performance limitations for specific products may be listed on the applicable catalog pages. 5 6 Id. ¶ 99. 7 Plaintiffs are California and Arizona homeowners with homes containing Simpson’s 8 Products in the concrete foundations. Id. ¶¶ 18-19, 24, 26, 31, 33, 38, 40, 45, 47, 53. Plaintiffs 9 assert Simpson’s Products are inherently defective and prone to premature corrosion, thereby 10 beaching Simpson’s express warranty. Id. ¶ 123. 11 B. Procedural Background 12 On December 2, 2019, Plaintiffs Cary Cooper, Terri Cooper, and Fernandina Beach LLC 13 filed this suit against Simpson on behalf of themselves and others similarly situated. ECF No. 1. 14 On February 25, 2020, Plaintiffs Cary Cooper, Terri Cooper, Fernandina Beach LLC, Simon 15 Ngyugen and Thoai Doan filed an amended complaint against Simpson on behalf of themselves 16 and others similarly situated. ECF No. 28.2 On May 19, 2020, the Court granted Simpson’s 17 Motion to Dismiss Plaintiffs’ First Amended Complaint. ECF No. 57. 18 On June 16, 2020, Plaintiffs Simon Nguyen, Thoai Doan, Ravi Salhotra, Sandyha Salhotra, 19 Melissa Card, Kevin Sullins, Maurice Can Roekel, Cory Czarnick, and Nola Czarnick 20 (collectively, “Plaintiffs”) filed a Second Amended Complaint (“SAC”) on behalf of themselves 21 and others similarly situated, alleging Simpson’s marketing materials constituted false and 22

23 2 Both complaints alleged the same nine causes of action: (1) violation of California Consumers Legal Remedies Act, California Civil Code §1770(a)(5) and (a)(7); (2) violation of California 24 Unfair Competition Law—Unlawful Business Practice, California Business and Professions Code §17200 et seq for creating and selling an allegedly defective product; (3) violation of California 25 Unfair Competition Law—Unlawful Business Practice, California Business and Professions Code §17200 et seq for failing to disclose material safety facts regarding products; (4) violation of 26 Florida’s Deceptive and Unfair Trade Practices Act for a material omission regarding Simpson’s products; (5) breach of express warranty; (6) breach of implied warranty of fitness; (7) breach of 27 implied warranty of merchantability; (8) negligence; and (9) fraud, nondisclosure, and 1 misleading representations about the Products’ design, quality, durability, performance, technical 2 capabilities, and value. Id. at ¶ 133. The SAC alleged the following eight causes of action: (1) 3 violation of the California Consumers Legal Remedies Act (“CLRA”), California Civil Code § 4 1770(a)(5) and (a)(7); (2) violation of the California Unfair Competition Law (“UCL”), Unlawful 5 Business Practice, California Business and Professions Code § 17200 et seq.; (3) violation of the 6 UCL, Unfair Business Practice; (4) violation of the UCL, Fraudulent Business Practice; (5) 7 violation of the Arizona Consumer Fraud Act (“CFA”), A.R.S. § 44-1521 et seq.; (6) breach of 8 express warranty; (7) negligent misrepresentation; and (8) fraud. 9 On September 8, 2020, the Court granted in part and denied in part Simpson’s Motion to 10 Dismiss the SAC. ECF No. 101. The Court held that, although Plaintiffs had standing to assert 11 their claims and Plaintiffs suffered an injury in fact, Plaintiffs failed to plead fraud by omission, 12 fraud by misrepresentation, and negligent misrepresentation. Id. at 10-23. Accordingly, the Court 13 dismissed with prejudice all of Plaintiffs’ claims sounding in fraud and negligent 14 misrepresentation. Id. at 23.3 15 On August 20, 2021, Plaintiffs moved to certify the following three classes:

16 National Class: All individuals in the United States who own residential structures constructed with Simpson HD Strap-Tie 17 Holdowns and/or Simpson MAS Mudsill Anchors embedded in the foundations and all prior owners of residential structures who paid to 18 repair and/or replace Simpson HD Strap-Tie Holdowns and/or Simpson MAS Mudsill Anchors.

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