Syntel Sterling Best Shores Mauritius Limited v. The Trizetto Group, Inc.
- Lorna Schofield
- 1:15-cv-00211
- U.S. District Court · Southern District of New York
- 3
In Syntel v. The TriZetto Group, Judge Schofield denied Syntel’s motion to exclude Chuck Sanders’s testimony about software and similarity.
Syntel and TriZetto were affected by the ruling because the court allowed TriZetto’s witness, Chuck Sanders, to testify about the specified software and copyright-related issues.
What happened
In Syntel Sterling Best Shores Mauritius Limited v. The Trizetto Group, Inc., Syntel asked the court to exclude Chuck Sanders’s testimony about the relationship between TriZetto’s Data Dictionary tool and Facets 5.10, and about the similarity of related software.
Syntel relied on a rule requiring witnesses to have sufficient personal knowledge of matters about which they testify. The court explained that Sanders was serving as TriZetto’s corporate representative and had reviewed relevant company documents. The court also noted that Sanders had worked with the software for years and had testified in detail about it during his deposition.
Judge Lorna G. Schofield denied Syntel’s motion. The court held that Sanders could testify about whether the Data Dictionary tool was included within Facets 5.10, whether it was a derivative work sharing protected elements, its functionality, and whether Syntel’s D-2 Data Dictionary was substantially similar.
The detailed version
- Syntel Sterling Best Shores Mauritius Limited v. The Trizetto Group, Inc. · No. 1:15-cv-00211
- Lorna Schofield
- Sept. 30, 2020
Background
Plaintiffs and counterclaim defendants Syntel Sterling Best Shores Mauritius Limited and Syntel, Inc., together referred to as “Syntel,” moved under Federal Rule of Evidence 602 to exclude testimony from Chuck Sanders. The proposed testimony concerned three areas: whether TriZetto’s Data Dictionary tool was subsumed within Facets 5.10; whether the Data Dictionary tool was a derivative work based on Facets 5.10 and shared protectable elements; and the functionality of the Data Dictionary tool and whether Syntel’s D-2 Data Dictionary was substantially similar to it.
Analysis
Rule 602 permits a witness to testify only when there is enough evidence to support a finding that the witness has personal knowledge of the subject. The court explained that Sanders was a corporate representative under Rule 30(b)(6). Such a witness may testify on behalf of the corporation based on information known to the corporation and need not have personally observed every matter, so long as the witness can convey the corporation’s information.
The court found that Sanders had knowledge of the relevant subjects based on his review of TriZetto documents. It also found that he had personal knowledge based on his years of working with Facets and the Data Dictionary tool and that his deposition showed he could testify in detail about them. The court further relied on its earlier ruling allowing defendants to use Sanders’s testimony at summary judgment. Under the law-of-the-case doctrine, courts generally adhere to prior rulings in the same case unless there has been an intervening change in law, new evidence, or a need to correct clear error or prevent manifest injustice. The court found that Syntel had not shown any such basis for changing the earlier ruling.
Ruling
The court denied Syntel’s motion to exclude Sanders’s testimony. Sanders may testify about all three identified subjects: the relationship between the Data Dictionary tool and Facets 5.10, whether the Data Dictionary tool is a derivative work sharing protectable elements, and the functionality and substantial similarity of Syntel’s D-2 Data Dictionary. The court directed the Clerk of Court to close Docket No. 748.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.