Scientific Applications & Research Associates (SARA), Inc. v. Zipline International, Inc.

District Court, N.D. California·Decided December 6, 2024·No. 3:22-cv-04480·Unknown

Opinion

1 2 3 6 7 SCIENTIFIC APPLICATIONS & Case No. 3:22-cv-04480-JSC RESEARCH ASSOCIATES (SARA), INC., 8 Plaintiff, ORDER RE: NON-PARTY SEQUOIA 9 CAPITAL OPERATIONS, LLC’S v. MOTION FOR ATTORNEY’S FEES ZIPLINE INTERNATIONAL, INC., 11 Re: Dkt. No. 160 Defendant.

12 13 SARA sues Zipline for alleged infringement of U.S. Patent No. 7,606,115 (the ‘115 patent) 14 and trade secret misappropriation. (Dkt. No. 86.)1 Before the Court is third-party Sequoia’s 15 motion for attorney’s fees and costs incurred in responding to SARA’s third-party subpoena and 16 motion to compel, and in bringing this motion for fees. (Dkt. No. 160.) After carefully 17 considering the parties’ written submissions, the Court DENIES Sequoia’s motion for attorney’s 18 fees and costs. 20 Sequoia claims it incurred costs due to (1) SARA’s overly broad and burdensome 21 subpoena, (2) SARA reneging on agreements concerning the subpoena, and (3) the need to 22 respond to a meritless motion to compel. 23 SARA initially subpoenaed Sequoia on June 30, 2023, requesting Sequoia’s documents 24 relating to its valuation of Defendant Zipline. (Dkt. No. 127-1 at 4-6.) In response, Sequoia 25 informed SARA of SARA’s need to first attempt to obtain the information from Zipline directly. 26 (Id. at 71.) SARA then exhausted efforts to obtain any overlapping documents from Zipline. (Id.) 27 1 After failing to obtain the documents at issue from Zipline, SARA reestablished contact with 2 Sequoia on May 10, 2024, requesting a meet and confer approximately two months before the 3 close of discovery. (Id. at 71-73.) To help narrow its request, SARA identified six key exemplary 4 documents responsive to the subpoena and Sequoia agreed to produce one document which, upon 5 review, SARA alleged did not satisfy its subpoena. (Id. at 78.) 6 With two days remaining in fact discovery, Sequoia offered a “small production” of 7 materials without explanation for what they would include or when they would be produced aside 8 from “this week.” (Id. at 77.) Although SARA offered its availability to hold a final meet and 9 confer over the course of the two remaining days of fact discovery, Sequoia instead produced the 10 small production of materials previously referenced and made themselves available for another 11 meet and confer after the close of fact discovery. (Id. at 76-77.) SARA still did not believe 12 Sequoia had satisfied its obligations, and with fact discovery now closed, it filed a motion to 13 compel, which the Court denied because SARA did not “persuasively explain[] how the third- 14 party investors’ independent evaluations (let alone evaluations beyond what has been produced) 15 are relevant to a claim or defense in this action.” (Id. at 75-76; Dkt. No. 153 at 1, 7.) Sequoia 16 thereafter filed the now pending Motion for Attorney’s Fees and Costs. (Dkt. No. 160.) 18 Rule 45 of the Federal Rules of Civil Procedure governs sanctions on parties serving third- 19 party subpoenas: A party or attorney responsible for issuing and serving a subpoena 20 must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The issuing court must 21 enforce this duty and impose an appropriate sanction—which may include lost earnings and reasonable attorney’s fees—on a party or 22 attorney who fails to comply. 23 Fed. R. Civ. Proc. 45(d)(1). Despite this broad language, “[m]erely losing a motion to compel 24 does not expose a party to Rule 45 sanctions.” Legal Voice v. Stormans Inc., 738 F.3d 1178, 1185 25 (9th Cir. 2013). And, while failure to narrowly tailor a subpoena may make sanctions appropriate, 26 “the district court need not impose sanctions every time it finds a subpoena overbroad; such 27 overbreadth may sometimes result from normal advocacy, which we have said should not give rise 1 for an improper purpose, or in a manner inconsistent with existing law.’” Id.; see also Mount 2 Hope Church v. Bash Back!, 705 F.3d 418, 429 (9th Cir. 2012) (holding that “absent undue burden 3 imposed by an oppressive subpoena, a facially defective subpoena, or bad faith on the part of the 4 requesting party, Rule 45(c)(1) sanctions are inappropriate.”) For example, a party may issue a 5 subpoena in a manner inconsistent with existing law if it does not “‘follow the subpoena 6 procedures in Rule 45,’ such as failure to notify opposing counsel of the subpoenas or requesting 7 information that is wholly irrelevant under any legal theory.” Fujikura, 2015 WL 5782351, at *8 8 (quoting Mount Hope Church, 705 F.3d at 428). In every circumstance, however, the court should 9 place “more emphasis on the recipient’s burden than on the issuer’s motives.” Mount Hope 10 Church, 705 F.3d at 428-29. A district court has discretion whether to issue sanctions pursuant to 11 Rule 45(d)(1). See Legal Voice, 738 F.3d at 1185. 12 In sum, Rule 45(d)(1) sanctions are discretionary and require evidence of an “undue 13 burden imposed by an oppressive subpoena, a facially defective subpoena, or bad faith on the part 14 of the requesting party.” Id.; Mount Hope Church, 705 F.3d at 429. 15 1. Sequoia is Not Entitled to Fees for Responding to SARA’s Subpoena 16 Sequoia argues SARA’s subpoena was overbroad because it contained requests which 17 “should have [been] directed to the other party in this action, Zipline.” (Dkt. No. 160 at 6.) But 18 while SARA served the subpoena on Sequoia before seeking documents from Zipline, once 19 Sequoia objected, and before Sequoia responded to the subpoena, SARA attempted to first compel 20 the documents from Zipline: 21 Consistent with the case law in your objections, we have attempted to obtain these documents from Zipline…Zipline has either claimed that 22 it does not have such documents in its possession, or has chosen not to produce such documents, leaving us with no further recourse but to 23 obtain the requested documents from you. 24 (Dkt. No. 127-1 at 71.) Sequoia’s reliance on Moon v. SCP Pool Corp. is unpersuasive because 25 there the court granted the third party’s motion to quash because the plaintiff did not first attempt 26 to obtain the documents from the defendant. 232 F.R.D. 633, 638 (C.D. Cal. 2005); see also In re 27 Subpoena to Apple Inc., No. 3:13-CV-254-MOC-DSC, 2014 WL 2798863, at *3 (N.D. Cal. June 1 19, 2014) (denying motion to compel because the plaintiff did not provide “any reason why it 2 [could not] obtain the requested information from [the defendant].”). 3 Duong v. Groundhog Enterprises, Inc., does not persuade the Court either. No. 19-CV- 4 01333 DMG-MAA, 2020 WL 2041939 at *7 (C.D. Cal. 2020). As explained above, SARA 5 attempted, albeit belatedly, to obtain the subpoenaed information from Zipline, and only upon not 6 receiving it did they turn (again) to Sequoia. (See Dkt. No. 127-1 at 71.) Further, in Duong the 7 court found sanctions appropriate based on a declaration offering specific evidence of the undue 8 burden the subpoena imposed on the third party. See 2020 WL 2041939 at *9. This evidence 9 included details such as the time required to locate and produce documents, the number of 10 employees involved, the estimated cost, and the volume of transaction records. Id. By contrast, 11 Sequoia’s claims of burden rely solely on vague, conclusory statements, lacking similar detailed 12 support. (See Dkt. No. 160-1 at 2-5.) 13 2.

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Scientific Applications & Research Associates (SARA), Inc. v. Zipline International, Inc., (N.D. Cal. 2024).

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Related

Mount Hope Church v. Bash Back!
705 F.3d 418 (Ninth Circuit, 2012)
Stormans Inc v. Mary Selecky
738 F.3d 1178 (Ninth Circuit, 2013)
Moon v. SCP Pool Corp.
232 F.R.D. 633 (C.D. California, 2005)