Spectrum Dynamics Medical Limited v. General Electric Company
- Vernon Broderick
- 1:18-cv-11386
- U.S. District Court · Southern District of New York
- 6
In Spectrum Dynamics v. General Electric, Magistrate Judge Parker granted General Electric’s protective-order motion, so it need not answer 1,672 requests for admission.
General Electric was not required to answer Spectrum’s 1,672 requests for admission. Spectrum may still seek the relevant information through document requests, interrogatories, and depositions, which the court identified as more appropriate discovery methods.
What happened
Spectrum Dynamics accused General Electric of violating a nondisclosure agreement and using its trade secrets, while General Electric asserted patent infringement claims. During discovery, Spectrum asked General Electric to admit facts about more than 60 people’s access to Spectrum’s information.
Spectrum served 1,672 requests for admission, including paired requests asking whether each person had signed the agreement, was bound by it, or accessed information during particular years. General Electric argued that the requests were meant to obtain new information, were burdensome, and were improper under the discovery rules.
The court held that the information was relevant and discoverable but that requests for admission were not the proper method for obtaining it. Magistrate Judge Katharine H. Parker granted General Electric’s motion for a protective order, and General Electric was not required to answer the requests.
The detailed version
- Spectrum Dynamics Medical Limited v. General Electric Company · No. 1:18-cv-11386
- Vernon Broderick
- Feb. 25, 2021
Background
Spectrum Dynamics Medical Limited sued General Electric Company in a patent and trade-secret dispute. Spectrum alleged that General Electric violated a nondisclosure agreement and incorporated some of Spectrum’s trade secrets into General Electric devices. General Electric asserted that Spectrum infringed two of its patents.
The parties had entered into a nondisclosure agreement while General Electric was considering an acquisition involving Spectrum or its nuclear molecular imaging business and technologies. Spectrum’s confidential information was disclosed to certain General Electric employees between 2009 and 2012. More than 60 General Electric-affiliated people had access to the information during the due-diligence process, but Spectrum did not know whether everyone with data-room access actually received trade-secret information or whether the information was shared with others.
Spectrum had already served document requests and interrogatories seeking information about access to its information. It then served requests for admission concerning more than 60 individuals. The requests asked, among other things, whether each person had signed a particular agreement, was bound by its confidentiality obligations, accessed Spectrum information during particular years, or accessed the data room during particular years. Altogether, Spectrum served 1,672 individual requests for admission.
The Motion
General Electric moved for a protective order. It argued that the requests were designed to obtain new information rather than confirm facts and narrow issues for trial. General Electric also argued that the requests were unduly burdensome, oppressive, and intended to harass.
Court’s Analysis
Federal Rule of Civil Procedure 36 allows requests for admission to determine whether the responding party admits a matter or considers it genuinely disputed for trial. The court explained that requests for admission help establish facts that do not need to be proved at trial; they are not a substitute for document requests, interrogatories, or depositions used to discover information.
The court found that Spectrum’s requests were more like contention interrogatories—questions seeking information about a party’s position—than requests designed to confirm facts and eliminate trial issues. The requests also exceeded the 25-interrogatory limit in Federal Rule of Civil Procedure 33, and the court viewed them as an attempt to circumvent that limit. Although Rule 36 has no numerical limit, the court said that requests can still be so numerous or framed in such a way that they become unduly burdensome.
The court concluded that answering 1,672 individual requests was undoubtedly unduly burdensome. It agreed that the information Spectrum sought was relevant and discoverable under Federal Rule of Civil Procedure 26, but determined that document requests, interrogatories, and depositions were the appropriate ways to obtain it.
Disposition
The court granted General Electric’s motion for a protective order. General Electric was not required to answer the requests for admission. The order addressed the discovery method and burden; it did not decide the parties’ patent, trade-secret, or nondisclosure-agreement claims.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.