Access Optical Networks, Inc. v. Seagate Technology LLC

Background

Access Optical Networks, Inc. (AON) alleges that it owns trade-secret information related to holographic data storage technology. It alleges that it shared trade secrets and confidential information with Seagate Technology LLC between 2012 and 2015 under nondisclosure agreements during discussions about a possible collaboration or investment. AON asserts claims for trade-secret misappropriation under the California Uniform Trade Secrets Act, trade-secret misappropriation under the federal Defend Trade Secrets Act, and breach of contract.

AON served an amended trade-secret disclosure on March 11, 2025. Seagate moved to compel AON to amend that disclosure and requested a protective order staying discovery until AON identified its trade secrets with reasonable particularity under California Code of Civil Procedure § 2019.210. AON opposed the motion and the requested stay. The parties agreed that discovery relating to the claims could not begin until AON made a compliant disclosure.

Legal standard

Section 2019.210 requires a party alleging trade-secret misappropriation under California law to identify the trade secret with “reasonable particularity” before beginning related discovery. The requirement is intended to promote investigated claims, prevent discovery from being used to obtain an opponent’s trade secrets, help the court define discovery’s scope, and allow the defendant to prepare a defense.

The court explained that reasonable particularity does not require a claimant to describe every detail of a trade secret or prove the claim before discovery begins. The disclosure must provide enough detail to distinguish the alleged trade secrets from general knowledge or specialized knowledge in the field, allow the defendant to investigate, and permit the court to control discovery. The required level of detail depends on the alleged trade secrets and the technology involved. The court also stated that disclosures should be construed liberally and that reasonable doubts should be resolved in favor of allowing discovery to proceed.

Discussion and ruling

Seagate argued that AON’s disclosure was not tied to the information AON alleged it shared with Seagate. The court rejected that argument. Based on the operative complaint and the parties’ briefing, the court was not persuaded that AON’s claims were limited to trade-secret information shared in writing. AON could refer to documents describing or evidencing written disclosures, but it was not required to do so. The court denied Seagate’s motion to compel on this ground.

Seagate also argued that AON used vague descriptions involving the “knowledge” or “use” of broad concepts and techniques. The court found that some alleged trade secrets were insufficiently specific about the confidential insights, practices, methods, or applications AON claimed to have shared. It required AON to clarify TS 2 and TS 11 and to identify the particular components claimed in TS 3. The court applied the same concern to TS 12 and TS 16. It granted Seagate’s motion to compel on this ground as to TS 2, 3, 11, 12, and 16, while denying it as to the remaining alleged trade secrets on that ground. The court added that AON would need to amend the other descriptions too if it intended to claim a more specific implementation that it had not disclosed.

Seagate further argued that several alleged trade secrets were generally known or disclosed in holographic-data-storage textbooks or AON’s own patent. The court held that AON did not have to prove in the disclosure that its alleged trade secrets were unknown to others. But if AON claimed that a trade secret went beyond textbook-level information or information in its published patent documents, it had to describe the trade secret clearly enough for Seagate to identify and investigate that distinction. The court concluded that TS 2, 9, 16, and 17 should be amended for this reason. It granted in part and denied in part Seagate’s motion to compel on this ground.

Finally, Seagate argued that AON improperly used vague “catch-all” language in TS 10. The court found that AON’s explanation reflected a fair reading of the disclosure and was not persuaded that AON had used improper catch-all language. It denied Seagate’s motion to compel on that ground.

Result

The court granted in part and denied in part Seagate’s motion to compel. AON was required to amend its disclosure for TS 2, 3, 9, 11, 12, 16, and 17 consistently with the order and to serve the amended disclosure by June 6, 2025. AON could amend its other alleged trade secrets if it wished to address Seagate’s concerns. Discovery could proceed as to all trade secrets other than TS 2, 3, 9, 11, 12, 16, and 17. Discovery concerning those seven trade secrets could proceed after AON served a disclosure complying with the order.