Largan Precision Co, LTD v. Motorola Mobility, LLC.
- Jeffrey White
- 4:21-cv-09138
- U.S. District Court · Northern District of California
- 5
In Largan Precision v. Motorola Mobility, Judge White granted Motorola’s request for letters rogatory to seek supplier documents without changing prior production duties.
Motorola and Largan, as well as the five China-headquartered suppliers from which Motorola seeks documents.
What happened
Largan Precision Co, LTD v. Motorola Mobility, LLC is a patent-infringement case involving Motorola’s request to seek documents from five suppliers headquartered in China. Motorola said the suppliers had relevant information about accused camera-lens products and other documents.
Largan opposed the request, arguing that it was unnecessary, duplicative, and intended to delay or avoid Motorola’s existing obligation to produce documents. Largan did not dispute that the requested documents were relevant and discoverable.
Judge Jeffrey White granted Motorola’s motion for letters rogatory but said the decision did not determine that this was the best or only way to obtain the documents and did not change Motorola’s earlier production obligations. Motorola must file proposed letters rogatory for the court’s approval by September 19, 2024.
The detailed version
- Largan Precision Co, LTD v. Motorola Mobility, LLC. · No. 4:21-cv-09138
- Jeffrey White
- Sept. 16, 2024
Background
This patent-infringement case involved a joint discovery letter concerning Motorola’s request for letters rogatory. A letter rogatory is a formal request from a court in one country to a court or other judicial authority in another country to perform a judicial act, such as taking evidence or obtaining documents.
Motorola sought letters rogatory directed to five suppliers headquartered in China: ZheJiang Sunny Opticals Co., Ltd.; AAC Acoustic Technologies (Shenzhen) Co., Ltd.; Chongqing TS-Precision Technology Co., LTD.; Kunshan Q Technology Limited; and O-Film Group Co. Ltd. Motorola sought documents in several categories concerning accused camera-lens assembly products and other relevant matters.
Largan opposed the request. It argued that the letters rogatory were unnecessary and duplicative and that Motorola was attempting to delay or avoid complying with an earlier order requiring Motorola to produce responsive documents that were within its control through contractual inspection and audit rights. Largan also argued that Motorola could obtain documents concerning AAC through other contractual suppliers.
Legal standard
The court explained that issuing letters rogatory is discretionary. In deciding whether to issue them, a court generally does not weigh the evidence sought or predict whether the evidence will actually be obtained. The request must be evaluated under Federal Rule of Civil Procedure 28(b) and the discovery scope in Rule 26(b)(1), which permits discovery of nonprivileged information relevant to a claim or defense and proportional to the needs of the case.
Ruling
The court found that the relevance of the requested documents was undisputed. It also concluded that Largan had not provided enough detail about the specific requests or any overlap with its earlier requests for the court to evaluate the objection that the letters rogatory were unnecessary and duplicative.
The court therefore granted Motorola’s motion for issuance of letters rogatory. It stated that the ruling did not mean letters rogatory were the best or only way for Motorola to obtain and produce documents from its overseas suppliers. The ruling also did not affect Motorola’s obligations under the earlier order. By no later than September 19, 2024, Motorola was required to file the proposed letters rogatory for the court’s approval.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.