hiQ Labs, Inc. v. Linkedin Corporation

Background

hiQ asked the district court for relief from Judge Kim’s April 26, 2022, nondispositive pretrial order. Judge Kim had denied hiQ’s request to require LinkedIn to produce documents concerning LinkedIn’s conduct toward other competing companies, including other data scrapers.

Arguments and Analysis

Under Rule 72(a) of the Federal Rules of Civil Procedure, a party may object to a magistrate judge’s ruling on a nondispositive matter. The district court may sustain the objection only if the ruling is clearly erroneous or contrary to law. A ruling is clearly erroneous when the district judge has a definite and firm conviction that a mistake was made.

hiQ argued that Judge Kim improperly applied a heightened “direct relevance” standard. The court rejected that argument, concluding that Judge Kim’s reference to information being “directly relevant” reflected an assessment of the information’s probative value rather than an incorrect legal standard. The court also concluded that Judge Kim did not clearly err in finding evidence concerning other competitors only tangentially related to LinkedIn’s intent toward hiQ.

hiQ separately argued that Judge Kim misunderstood hiQ’s claim under section 17200, including its unfairness theory, by treating it as equivalent to the federal antitrust claims that the court had dismissed. The court rejected that argument after considering the broader context of Judge Kim’s order.

Finally, hiQ challenged Judge Kim’s conclusion that, even if the requested information were relevant, the burden of producing the broad discovery at that late stage of the litigation outweighed the case’s needs. Based on the record concerning the burden of the requested discovery, the court concluded that Judge Kim did not clearly err.

Disposition

Judge Edward M. Chen denied hiQ’s motion for relief. The order stated that it disposed of Docket No. 262.