Power Integrations, Inc. v. Silanna Semiconductor North America, Inc.

Background

Power Integrations, Inc. asked for leave—that is, permission—to file a motion asking the court to reconsider an earlier interlocutory order. The earlier order granted The Penbrothers International Inc.’s motion to dismiss for lack of personal jurisdiction. The opinion refers to that earlier order as the “dismissal order.”

Under the Northern District of California’s local rule, a party must obtain permission before seeking reconsideration of an interlocutory order. The party must show a material difference in fact or law, newly emerged material facts or a change in law, or that the court failed to consider material facts or dispositive legal arguments previously presented. The party also may not simply repeat arguments already made in connection with the earlier order.

Power Integrations’ Arguments

Power Integrations argued that the court relied on Hudnall v. Payne when denying its requests for jurisdictional discovery and leave to amend, even though Power Integrations did not have an opportunity to address that case because it was raised during the rebuttal portion of oral argument. Power Integrations also argued that the dismissal order failed to consider allegations in its First Amended Complaint about an alleged conspiracy between Penbrothers and Silanna to recruit Power Integrations engineers to work for Silanna in California.

Court’s Analysis

The court said Power Integrations mischaracterized the dismissal order and the record. According to the court, the denial of jurisdictional discovery was based first on Power Integrations’ having offered only a “hunch” that discovery would show communications between Penbrothers and Silanna in California. The court further explained that, even if such communications existed, communications by mail, telephone, or other international means ordinarily would not qualify as purposeful activity supporting personal jurisdiction over an out-of-state defendant.

The court also rejected the argument that Power Integrations lacked an opportunity to address the relevant authority. It noted that Power Integrations had argued in its opposition brief and at oral argument that it should be allowed to investigate Penbrothers’ communications with Silanna. The court therefore viewed the reconsideration request as repeating an argument it had already considered.

The court likewise rejected the argument concerning the alleged conspiracy. It stated that the First Amended Complaint did not identify where most of the relevant acts occurred, including acts connected to the alleged conspiracy. To the extent Power Integrations argued that discovery might reveal communications in California, the court rejected that argument for the reasons given in the dismissal order. To the extent Power Integrations argued that Penbrothers’ possible anticipation of effects on Power Integrations in California supported personal jurisdiction, the court said that argument had also been made and rejected earlier.

Disposition

The court concluded that all of Power Integrations’ arguments had been presented and considered in connection with Penbrothers’ motion to dismiss. Power Integrations had not shown a material difference in fact or law, new material facts, a change in law, or the court’s failure to consider material facts or dispositive legal arguments. The court therefore denied the motion for leave to file a motion for reconsideration.