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N.D. Cal.Substantive rulingFiled Nov. 16, 2021

MaxPower Semiconductor, Inc. v. ROHM Co. Ltd.

Judge
Vince Chhabria
Docket
3:21-cv-08697
Court
U.S. District Court · Northern District of California
Pages
3
ArbitrationPreliminary InjunctionCivil Procedure
In one sentence

In MaxPower Semiconductor v. ROHM, Judge Chhabria compelled arbitration, granted emergency relief, and ordered ROHM to explain potential sanctions.

Who this affects

MaxPower Semiconductor, Inc. and ROHM Co. Ltd.; the order also affected ROHM’s patent-related proceedings before the CNIPA and in Korea and Taiwan, and required ROHM to address possible sanctions.

What happened

In MaxPower Semiconductor, Inc. v. ROHM Co. Ltd., the court enforced the parties’ arbitration agreement and rejected ROHM’s argument that the court lacked authority over it. The court also found that agreeing to arbitrate in California supported California courts’ authority over ROHM.

The court granted MaxPower’s request to compel arbitration and its request for emergency relief. ROHM was ordered to join MaxPower in seeking to end a proceeding before the CNIPA and to seek stays or termination of proceedings in Korea and Taiwan. The court also ordered ROHM to explain why it should not be sanctioned for unreasonably and vexatiously multiplying the proceedings.

Judge Vince Chhabria issued the order. The order also granted MaxPower’s motion to seal and allowed MaxPower to respond to ROHM’s sanctions filing, including any request for attorney fees.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
MaxPower Semiconductor, Inc. v. ROHM Co. Ltd. · No. 3:21-cv-08697
Judge
Vince Chhabria
Date
Nov. 16, 2021

Background

MaxPower asked the court to enforce a contract requiring arbitration of disputes with ROHM. The contract designated arbitration in Santa Clara County, California. ROHM argued that the court lacked personal jurisdiction—legal authority over ROHM—but the court rejected that argument as frivolous. The court reasoned that ROHM’s agreement to arbitrate in California implicitly consented to the jurisdiction of California courts.

The court noted that it had previously addressed the arbitration agreement in related proceedings. It stated that the fact that the current proceedings involved ROHM rather than a subsidiary did not change the analysis because the arbitration clause was in a contract between MaxPower and ROHM.

Rulings and Orders

The court granted MaxPower’s petition to compel arbitration and its motion for a preliminary injunction and emergency relief. It adopted the reasons stated in an earlier related proceeding and concluded that the fact that the disputes were pending before foreign adjudicatory bodies did not prevent the court from granting relief. The court found that allowing the patent proceedings to continue would permanently eliminate arbitration’s advantages of speed and lower cost.

The court ordered ROHM to join MaxPower in moving to terminate the proceeding pending before the CNIPA by November 18, 2021. It also ordered ROHM to join MaxPower in moving within seven days to stay or terminate the proceedings pending in Korea and Taiwan. Those motions were to request a stay first and to state that the parties sought termination if a stay was denied. The order stated that ROHM could resume efforts to invalidate MaxPower’s patents if the arbitrator determined that the disputes were not subject to arbitration.

The court also granted MaxPower’s motion to seal. It ordered ROHM to file, within 14 days, a brief explaining why it should not be sanctioned under 28 U.S.C. § 1927 for unreasonably and vexatiously multiplying the proceedings. MaxPower could respond within seven days. If MaxPower sought attorney fees based on a possible violation, it was required to provide a detailed description of the fees it claimed. The order set a hearing for January 6 at 10:00 a.m., but the opinion lists that hearing date as January 6, 2021, which predates the November 16, 2021 order.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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