Teradata Corporation v. SAP SE

Background

The court had previously ordered Teradata to drop trade-secret claims for which it had not provided a complete response to SAP’s Interrogatory No. 3, unless Teradata showed good cause. That interrogatory asked Teradata to identify each allegedly misappropriated trade secret and provide the factual basis for its belief that SAP’s use, disclosure, or other alleged misappropriation was not permitted by the parties’ Bridge Project Agreements.

Teradata’s updated response reduced its list from 146 pending trade-secret claims to 55 identified alleged misappropriated trade secrets. SAP contended that Teradata still had not provided facts explaining how SAP misappropriated 48 of those 55 trade secrets. SAP sought to strike Trade Secret Nos. 1 through 1.27 and 24 through 43. The first group concerned information in Teradata’s “Orange Book,” and the second concerned Teradata’s “Select For All Entries” claims.

Arguments

SAP relied on the court’s case-management authority under Federal Rule of Civil Procedure 16 and argued that the court should enforce its earlier order. SAP also cited decisions involving limits on asserted claims and dismissal for failure to comply with court requirements.

Teradata argued that SAP’s request was a premature summary-judgment motion presented as a motion to strike. Teradata noted that fact and expert discovery were still ongoing, asserted that it had complied with the court’s order by removing 91 claims, and pointed to the parties’ agreement to reduce the claims further before summary judgment and trial. Teradata also argued that its response was sufficient at that stage because it identified high-level evidence that Teradata had conveyed trade secrets to SAP during the Bridge Project and that SAP had used them in developing HANA.

Ruling

The court denied SAP’s motion to enforce. It noted that SAP did not dispute that Teradata had provided a supplemental response and had dropped 91 unsupported trade-secret claims. SAP also did not argue that it could not understand the bases of the remaining claims or identify any specific prejudice, such as prejudice concerning the scope of ongoing discovery.

The court concluded that SAP was instead challenging the sufficiency and level of detail of Teradata’s response, including whether Teradata identified when or who at SAP allegedly misappropriated each trade secret. Because discovery was ongoing and the parties had agreed that Teradata would soon reduce the claims it intended to pursue through trial, the court found no need to test the supplemental response at that time. The court stated that the reduced set of claims would be tested on summary judgment and at trial.

The court also granted the administrative motions to file under seal identified by Docket Nos. 305, 325, and 328. Those motions sought to seal information revealing technical details and internal discussions about product development. The opinion does not state that the court decided the merits of Teradata’s trade-secret claims.