Monolithic Power Systems, Inc. v. Dong
- Jeffrey White
- 4:20-cv-06752
- U.S. District Court · Northern District of California
- 3
In Monolithic Power v. Dong, Judge Beeler ordered trade-secret identification before discovery, applying California law to contract and fraud claims.
Monolithic Power Systems, Inc. and the former employees sued as defendants, because the order required Monolithic to identify the alleged trade secrets before related discovery could proceed.
What happened
Monolithic Power Systems sued former employees for allegedly stealing confidential information, asserting breach-of-contract and fraud claims. The parties disputed whether California law required Monolithic to identify its trade secrets specifically before discovery began.
The court held that California Civil Code section 2019.210 applied because the claims were essentially about trade-secret misappropriation, even though the amended complaint used the term “confidential information” and asserted contract and fraud theories. The court ordered Monolithic to identify the trade secrets with reasonable particularity before related discovery; the order did not affect discovery unrelated to trade secrets.
Judge Laurel Beeler issued the discovery order on August 26, 2021, disposing of the parties’ joint discovery letter.
The detailed version
- Monolithic Power Systems, Inc. v. Dong · No. 4:20-cv-06752
- Jeffrey White
- Aug. 27, 2021
Background
Monolithic Power Systems, Inc. sued former employees for breach of contract based on employment agreements and for fraud. Monolithic alleged that the former employees stole its confidential information. The dispute addressed whether Monolithic had to identify its trade secrets with reasonable particularity before beginning discovery related to those alleged secrets.
Monolithic argued that California Civil Code section 2019.210 applied only to claims brought under the California Uniform Trade Secrets Act. The defendants responded that courts in the Northern District of California routinely required this type of disclosure.
The opinion also discussed Monolithic’s earlier complaint, which asserted breach of contract, a Computer Fraud and Abuse Act claim, and fraud while alleging trade-secret misappropriation. The trial court dismissed that complaint in part, applying the California Uniform Trade Secrets Act’s preemption provision. The amended complaint dropped the Computer Fraud and Abuse Act claim and used “confidential information” instead of “trade secret,” but the court viewed the core of the claims as unchanged.
Court’s Analysis
Section 2019.210 provides that, in an action alleging trade-secret misappropriation under the California Uniform Trade Secrets Act, the party alleging misappropriation must identify the trade secret with reasonable particularity before beginning trade-secret discovery, subject to appropriate protective orders.
The court followed decisions applying section 2019.210 beyond claims formally pleaded under the California Uniform Trade Secrets Act. Those decisions reasoned that the statute applies to an action alleging misappropriation of a trade secret and is not limited to a particular cause of action. The court concluded that the statute applied here because Monolithic’s contract and fraud claims were, in substance, claims for trade-secret misappropriation.
Ruling
The court ordered Monolithic to comply with section 2019.210 by identifying the trade secrets with reasonable particularity before trade-secret discovery. The order did not affect discovery requests that were unrelated to trade secrets. The court stated that the order disposed of ECF No. 43.
Judge Laurel Beeler issued the order and signed it as a United States Magistrate Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.