MPHASIS Corporation v. Rojas

Background

Mphasis Corporation moved for a temporary restraining order and a preliminary injunction against its former employee, Albert Rojas, based on alleged trade-secret misappropriation. At a May 6, 2025 conference, Rojas appeared without counsel and consented in part to the temporary restraining order. The court granted that request and later sought additional briefing on the preliminary-injunction motion.

The temporary restraining order barred Rojas from disclosing or using Mphasis’s confidential information, trade secrets, and other confidential or proprietary materials, including Mphasis emails and documents created or used for Mphasis’s clients. The court stated that, after the order was entered, Rojas disseminated Mphasis work product on the docket and to nonparties, including Mphasis’s client QBE. The court concluded that this conduct showed that Mphasis faced a risk of harm to its client relationships.

Preliminary Injunction

The court granted Mphasis’s motion for a preliminary injunction for substantially the reasons given in Mphasis’s memorandum. It emphasized that Rojas’s opposition was conclusory. Rojas argued that his disclosures were protected whistleblower activity under state and federal statutes, but he cited no supporting authority and did not explain why those statutes covered his possession and dissemination of Mphasis’s confidential information. The court also found his other objections—including assertions that Mphasis suffered no irreparable harm, that the lawsuit was unlawful retaliation, and that the injunction would violate his constitutional rights—insufficiently supported.

The court denied Rojas’s request for an evidentiary hearing because he did not identify any specific, essential factual dispute requiring one, and the court found that the disputes could be resolved on the written record. It also denied his request to redact or seal portions of the temporary restraining order, finding that his stated concern about reputational harm and chilled disclosures was not compelling enough to overcome the strong presumption that materials supporting the court’s decision should be publicly accessible. The court stated that the preliminary injunction would be entered in a separate order that day.

Other Motions

The court denied Rojas’s duplicative and premature motions for summary judgment. It explained that summary judgment generally should be considered after discovery and that this was not one of the rare cases in which summary judgment should be granted before the nonmoving party has had an opportunity to obtain essential information. The court also noted the tension between Rojas’s request for summary judgment and his assertion that material factual disputes existed.

The court denied Rojas’s motion to join QBE as a necessary party because the motion contained only unsupported assertions that complete relief could not be granted without QBE or that QBE’s absence could create inconsistent obligations. The court denied without prejudice Rojas’s renewed motions for permission to file a third-party complaint against QBE. Because Rojas had not yet filed an answer, the court stated that permission was not required at that stage.

The court also denied Rojas’s motions to strike two declarations filed by Mphasis, concluding that disagreement with the declarations’ contents was not a proper basis for striking them. The court disregarded Rojas’s unauthorized sur-replies and treated one of two largely duplicative opposition filings as his opposition to the preliminary-injunction motion.

Disposition

Judge Jesse M. Furman granted the preliminary-injunction motion; denied Rojas’s motions for summary judgment, motions to strike, and motion to join QBE; and denied without prejudice the motions seeking permission to file a third-party complaint. The court extended Rojas’s deadline to answer the complaint to June 30, 2025, warned that missing the deadline could lead Mphasis to seek default judgment, and cautioned Rojas that excessive or duplicative filings could result in additional sanctions. The clerk was directed to terminate the docket entries identified in the opinion.