Micron Technology, Inc. v. Factory Mutual Insurance Company
- Laurel Beeler
- 3:18-cv-07689
- U.S. District Court · Northern District of California
- 9
In Micron Technology v. Factory Mutual, Judge Beeler partly denied and partly granted reconsideration, narrowing discovery and allowing insureds review time.
Micron Technology, Inc. and the other plaintiffs, Factory Mutual Insurance Company, and non-party insureds whose claim files may fall within the narrowed discovery order.
What happened
In Micron Technology, Inc. v. Factory Mutual Insurance Company, Factory Mutual asked the court to reconsider an order requiring it to produce information about other insureds’ claims involving similar policy language. Factory Mutual cited the burden of reviewing the files and objections from non-party insureds.
The court kept the discovery requirement but narrowed it to documents involving the interpretation or application of policy language in claims from the semiconductor industry. It also gave non-party insureds 14 days to review documents before production and required the parties to discuss protective-order changes or trade-secret redactions if objections remained.
Judge Laurel Beeler denied in part and granted in part Factory Mutual’s reconsideration motion. She denied as moot Factory Mutual’s alternative request to certify the discovery order for an immediate appeal.
The detailed version
- Micron Technology, Inc. v. Factory Mutual Insurance Company · No. 3:18-cv-07689
- Laurel Beeler
- Aug. 3, 2022
Background
Micron requested documents concerning other claims made after January 1, 2014, involving comparable losses and similar insurance-policy language. The requests included claims involving certain equipment faults or malfunctions, policy exclusions, and losses at specified times or places. The court’s earlier order required Factory Mutual to produce responsive documents for claims in the semiconductor industry, meaning semiconductor fabrication plants.
Factory Mutual moved for reconsideration under the Northern District of California’s local rule and Federal Rule of Civil Procedure 54(b). It argued that the court had not properly balanced the information’s relevance against the burden on Factory Mutual and non-party insureds. It also relied on details about the time spent preparing the files and objections from insureds who wanted to review the files, were concerned about disclosure to Micron, or were considering objecting directly. Alternatively, Factory Mutual asked the court to certify the discovery order for interlocutory appeal, meaning an appeal before the case ended.
Court’s analysis
The court found no change in controlling law and concluded that it had already considered relevance and burden. It continued to find the other claims potentially relevant to interpreting and applying the policy language. The court rejected Factory Mutual’s argument that Micron had to identify a particular policy ambiguity before obtaining the information, explaining that this was a discovery dispute and that the court had not ruled that the policy was unambiguous.
The court also concluded that the additional details about Factory Mutual’s document-review time did not justify reconsideration because they were not new or different from the burdens previously considered. It recognized, however, that the non-party insureds’ objections raised specific concerns about reviewing the files and protecting trade secrets. The court noted that Micron had been willing to consider changes to the protective order, but also recognized that such orders may not fully protect non-parties’ trade secrets.
Ruling
Judge Laurel Beeler denied in part and granted in part Factory Mutual’s motion for reconsideration. She amended the earlier order so that Factory Mutual must produce documents responsive to Micron’s Requests for Production Nos. 62–78 only when they concern claims in the semiconductor industry and involve the interpretation or application of policy language.
The court ordered that the documents be provided to the non-party insureds for review within 14 days of the order and gave those insureds an additional 14 days to review them before production. If an insured continued to object, the parties had to meet and confer about modifying the protective order or agreeing to redact trade secrets that the order could not adequately protect. The court denied as moot Factory Mutual’s request for interlocutory-appeal certification and stated that the order resolved ECF No. 234.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.