Access Optical Networks, Inc. v. Seagate Technology LLC

Background

Access Optical Networks, Inc. (AON) alleges that it owns trade secrets concerning 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, and that Seagate used the information to accelerate development of its own technology. AON asserts claims under the California Uniform Trade Secrets Act, the federal Defend Trade Secrets Act, and for breach of contract.

The parties had agreed that discovery on these claims could not begin until AON identified its trade secrets in sufficient detail under California Code of Civil Procedure section 2019.210. AON initially identified 22 alleged trade secrets. In a May 27, 2025 order, the court granted in part and denied in part Seagate’s earlier motion to compel, ordering AON to amend TS 2, 3, 9, 11, 12, 16, and 17 and allowing amendments to the other alleged trade secrets to address Seagate’s concerns.

AON later served a third amended disclosure identifying 76 alleged trade secrets. Seagate filed this second motion to compel, asking the court to strike certain alleged trade secrets or require AON to amend them further, and also sought sanctions.

Court’s analysis

For discovery-management purposes, the court used the “reasonable particularity” requirement as a guide. That requirement calls for enough detail to identify the alleged trade secret, allow the opposing party to investigate how it may differ from information already known, and allow the court to manage relevant discovery.

For TS 3, 12, and 16, the court held that AON continued to use broad terms such as “optical components,” “optical elements,” and “optics” without adequately identifying the particular components or configurations it claimed as trade secrets. The court found that the current disclosure was broader and less specific than the earlier one and did not adequately guide discovery.

For TS 2, 9, 16, and 17, the court held that AON still had not clearly stated what the alleged trade secrets were. The court said AON did not have to prove at the disclosure stage that its trade secrets differed from publicly known information, but it had to describe them clearly enough for Seagate to investigate that issue. The court found that AON’s use of general language and explanatory footnotes created uncertainty about the scope of the alleged trade secrets.

For TS 11, however, the court found that AON had complied with the prior order. The court understood AON’s disclosure to identify certain knowledge, its cause, and its benefits. The court stated that AON did not need to provide a specific example or explain the optimization at a more detailed level at this stage. Seagate remained free to argue that the claimed knowledge was already publicly known.

The court also rejected AON’s argument that the May 27 order authorized it to add more than 50 new alleged trade secrets. The prior order addressed the 22 previously identified alleged trade secrets and did not generally permit AON to add new ones. The court was not persuaded that the new alleged trade secrets should guide discovery, particularly because AON disclosed them four months after the scheduling-order deadline without adequate justification. The court did not decide whether those new alleged trade secrets otherwise satisfied the reasonable-particularity requirement.

Ruling

The court granted in part and denied in part Seagate’s motion. It denied Seagate’s motion to strike AON’s disputed alleged trade secrets as a discovery sanction. It ordered AON to promptly amend the disclosures for TS 2, 3, 9, 12, 16, and 17 to clarify their scope, warning that failure to do so could affect AON’s ability to obtain corresponding discovery of Seagate’s confidential information. The court found that AON had already complied with the clarification requirement for TS 11. The court also declined, as a matter of discovery management, to allow AON’s belatedly added alleged trade secrets to expand the scope of discovery.