Synchronoss Technologies v. Dropbox Inc

Background

Synchronoss Technologies, Inc. filed this patent-infringement action against Dropbox Inc. and others. The case originally began in the Northern District of New Jersey and was later transferred to the Northern District of California. Synchronoss alleged infringement of U.S. Patent Nos. 6,671,757, 7,587,446, and 6,757,696. On June 17, 2019, the court granted Dropbox summary judgment of non-infringement.

Dropbox’s Attorneys’ Fee Request

Under Section 285 of the Patent Act, a court may award reasonable attorneys’ fees to the prevailing party in an “exceptional” case. Dropbox argued that Synchronoss’s positions after claim construction were objectively unreasonable and that Synchronoss engaged in litigation misconduct.

The court rejected Dropbox’s arguments. Regarding the ’757 and ’446 Patents, the court agreed that its claim-construction order did not cover software alone, but found that Synchronoss had interpreted the construction—incorrectly, in the court’s view—as supporting its infringement theory. The court did not consider that position frivolous or exceptional. Regarding the ’446 Patent, Synchronoss had acknowledged an apparent problem in the claim language but argued that a technical expert would understand the claim differently. Although the court rejected that argument and found Dropbox’s position more persuasive, it held that losing the argument did not by itself make Synchronoss’s position objectively unreasonable.

The court also found that discovery disputes and motion practice did not amount to the misconduct needed to make the case exceptional. It described the case as hard-fought and zealously litigated in a manner that was routine for patent cases. The court further held that Dropbox’s allegations about inflated licenses and testimony by Synchronoss’s Chief Legal Officer, Ronald Prague, concerned alleged conduct before the litigation rather than the type of litigation misconduct that supports a fee award. The court found no clear evidence that Synchronoss had submitted incomplete or misleading evidence to the court.

Sealing Motions

The parties separately sought to seal portions of briefs and exhibits. The court applied a strong presumption of public access to judicial records and required compelling reasons for sealing records closely related to the merits. For records only tangentially related to the merits, the court applied the lower good-cause standard.

The court found that certain confidential agreements with third parties, financial terms, confidential licensing information, business information, and source code could be sealed. It denied sealing requests for information that the designating party no longer supported keeping secret, information lacking the required supporting declaration, information already publicly available elsewhere, and a citation to a public regulation. The court granted some requests in full, granted another in part, and denied other requests in whole or in part as specified in its filing-by-filing charts.

Disposition

The court DENIED Dropbox’s motion for attorneys’ fees. It GRANTED in part and DENIED in part the parties’ motions to seal. The parties were directed to electronically file revised submissions without redacting the information identified as nonsealable; other approved redactions could remain.