Cellspin Soft, Inc. v. Garmin International, Inc., et al.

Background

Cellspin Soft, Inc. and Garmin International, Inc., along with other defendants, submitted a discovery letter concerning Garmin’s request to add terms to the protective order in the California litigation. The proposed addendum would have allowed Garmin to use protected materials from that litigation in new actions brought by Cellspin against related entities in the Eastern District of Texas.

In an earlier June 17, 2026 order, the court held that Garmin had not met its burden of showing that the protected materials were relevant to the Texas actions. The court stated that Garmin needed to describe specifically the overlap between the cases, identify the document categories that would be relevant, and explain why those categories were relevant.

Court’s Analysis

The court again applied the rule that a party seeking to modify a protective order for use in related litigation must establish relevance. Although Garmin identified categories of documents in its renewed request, the court found that Garmin’s explanation of the overlap remained overbroad and conclusory.

Garmin argued that the cases involved the same patents, parties, and accused system. The court found that this repeated a general functionality argument that it had already rejected as insufficient. The court also found that Garmin appeared to rely on older infringement charts to argue that all versions of Bluetooth Low Energy operated in the same way for infringement purposes, without explaining how those charts applied to products in the Texas actions, particularly products that may have been introduced later.

The court likewise found that Garmin’s reliance on a 2021 expert report did not show that the expert’s opinion applied to the products in the Texas actions. The court also noted that Garmin did not adequately respond to Cellspin’s arguments about differences in applications, versions, sensors, firmware, Bluetooth Low Energy implementations, backend architectures, and other technical implementations. Garmin also did not adequately support its assertion that the cases involved the same parties or accused system, because the California case involved Garmin International and Garmin USA while the Texas action involved Garmin Corporation and Garmin Ltd.

Disposition

Judge Kandis A. Westmore again denied Garmin’s request for an addendum to the protective order. The denial was without prejudice. The order disposed of docket entry 270.