Medidata Solutions, Inc. v. Veeva Systems Inc.

Background

The court’s February 10, 2021 summary-judgment opinion granted summary judgment to Veeva on Plaintiffs’ New York state-law claims for tortious interference, unfair competition, aiding and abetting breach of fiduciary duties, and unjust enrichment, identified as Counts III through VI. That opinion held that California law applied to those claims under New York’s choice-of-law framework because California had a greater interest in the dispute, and that the claims were preempted by the California Uniform Trade Secrets Act to the extent they were based on the same alleged trade-secret misappropriation.

The current order addressed Count II, Plaintiffs’ common-law trade-secret-misappropriation claim. On summary judgment, the parties had disputed whether the alleged trade secrets were described specifically enough, whether they were valuable and protected, and whether Defendant took and used them. The earlier opinion applied New York and analogous federal law to those issues because it found no actual conflict between New York and California law on the specific issues raised at summary judgment. The court explained that this did not require New York law to govern Count II at trial.

Ruling

The court held that California law governs Count II at trial. It reasoned that California law applied for the reasons stated in the summary-judgment opinion, including California’s greater interest under New York’s choice-of-law framework. The court also ordered the parties to file proposed joint jury instructions and a verdict form by May 11, 2021.

Classification

This is a procedural order resolving which state’s law will govern at trial. It does not decide whether the alleged trade-secret misappropriation occurred or otherwise resolve the merits of Count II.