NantWorks, LLC v. Niantic, Inc.
- Laurel Beeler
- 3:20-cv-06262
- U.S. District Court · Northern District of California
- 4
In NantWorks v. Niantic, Judge Beeler denied reconsideration because good cause, diligence, and lack of prejudice supported Niantic’s amended invalidity contentions.
NantWorks, LLC and Niantic, Inc.; the ruling left in place Niantic’s permission to amend its patent-invalidity contentions.
What happened
NantWorks, LLC asked the court to reconsider its earlier decision allowing Niantic, Inc. to amend its patent-invalidity disclosures based on documents obtained from third parties.
NantWorks argued that the court had not applied the required good-cause standard, had wrongly found Niantic diligent, and had overlooked prejudice. The court rejected those arguments, finding that Niantic acted diligently under the overall case timeline, the amendment was limited, and it did not disrupt the schedule.
Judge Laurel Beeler denied NantWorks’s motion for reconsideration.
The detailed version
- NantWorks, LLC v. Niantic, Inc. · No. 3:20-cv-06262
- Laurel Beeler
- July 20, 2022
Background
The court had previously allowed Niantic, Inc. to amend its invalidity contentions—its required disclosures identifying grounds and supporting prior-art references for challenging patent validity. The court found good cause under Patent Local Rule 3-6 because Niantic’s amendment was limited, based on newly discovered information from third parties, and timely supplemented its earlier claim charts. The court also found no prejudice to NantWorks, LLC.
NantWorks moved for reconsideration of that earlier order. It argued that the court had not applied the good-cause standard, had incorrectly found Niantic diligent despite delays, and had overlooked prejudice to NantWorks.
Analysis
The court denied reconsideration. Under the Northern District of California’s local rule, reconsideration of an interlocutory order generally requires a showing that the court failed to consider material facts or dispositive legal arguments previously presented. The court also explained that reconsideration may be appropriate for clear error, but found no such error here.
The court said it had applied the good-cause standard. It found that Niantic had acted diligently when it served its initial contentions in March 2021, including identifying and developing the Google Maps Mobile, Layar, and Parallel Kingdoms references, serving subpoenas, investigating Layar, and preparing extensive claim charts. After receiving document productions from Layar, Google, and PerBlue, Niantic produced the PerBlue documents to NantWorks and served amended charts on the parties’ agreed date. The parties’ discussions then led Niantic to serve further amended charts.
The court rejected NantWorks’s focus on the number of days between receiving documents and amending the contentions. It evaluated the overall circumstances, including activity before and after a stay, the case-narrowing process, and the time reasonably needed to revise the charts. The court found that Niantic did not add new invalidity theories or contentions; it supplemented its charts with citations to newly received third-party materials.
The court also found no prejudice to NantWorks because the amendment did not disrupt discovery, motion deadlines, or the trial schedule. Finally, it rejected NantWorks’s argument that block quotations in Niantic’s amended charts violated Patent Local Rule 3-3, finding that the charts provided substantial notice and that the cited materials did not negate the finding of good cause.
Disposition
The court denied NantWorks’s motion for reconsideration and stated that the order resolved ECF No. 110. Judge Laurel Beeler signed the order on July 20, 2022.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.