Spectrum Dynamics Medical Limited v. General Electric Company
- Vernon Broderick
- 1:18-cv-11386
- U.S. District Court · Southern District of New York
- 4
Spectrum Dynamics v. General Electric: Judge Parker denied defendants’ motion to compel answers to a due-diligence document interrogatory.
The ruling affected Spectrum Dynamics Medical Limited and General Electric Company and the other defendants by allowing Spectrum not to answer Interrogatory 5 and denying the defendants’ motion to compel.
What happened
Spectrum Dynamics Medical Limited sued General Electric Company and others, and the defendants asked the court to require Spectrum to answer an interrogatory identifying documents shared during due diligence and explaining when, how, and with whom they were shared.
Spectrum objected that the interrogatory violated the district’s discovery rules and was overly broad and burdensome. The court found that Spectrum had already provided a detailed chart and documents containing the requested information, and that depositions were a more practical way to obtain any follow-up information.
Judge Katharine H. Parker ruled that Spectrum did not have to answer the interrogatory and denied the defendants’ motion at ECF No. 229.
The detailed version
- Spectrum Dynamics Medical Limited v. General Electric Company · No. 1:18-cv-11386
- Vernon Broderick
- Apr. 28, 2021
Background
Defendants General Electric Company and others moved to compel Plaintiff Spectrum Dynamics Medical Limited to answer Interrogatory 5. The interrogatory sought the Bates numbers of all documents Spectrum made available to one or more defendants during due diligence, along with information about how, when, and to which defendants each document was provided. It identified several possible sharing events, including the Spectrum Data Room, due-diligence meetings, communications through February 2012, and a June 2012 presentation.
Spectrum objected that the interrogatory violated Local Rule 33.3, which limits interrogatories at different stages of discovery. Spectrum also objected that the request was overly broad, burdensome, and not proportional to the needs of the case.
Court’s analysis
The court explained that Interrogatory 5 contained multiple discrete subparts and was outside the categories of interrogatories generally allowed at the beginning of discovery. It also was not a proper end-of-discovery contention interrogatory because discovery was far from complete. The request therefore was proper only if answering through an interrogatory was more practical than obtaining the information through a document request or deposition.
The court noted that Spectrum had already provided a detailed chart identifying the trade secrets it claimed were misappropriated, Bates numbers for documents reflecting those trade secrets, some documents attached to emails sent to defendants’ employees, the names of employees Spectrum believed received the documents, and approximate dates of delivery. The court had previously required Spectrum to provide that chart after a conference on the issue. Because defendants could not seek the same information again through an interrogatory, and because the documents and chart allowed defendants to determine the requested information, the court found the interrogatory improper. The court further stated that follow-up questions about the trade secrets and when they were exchanged could be obtained more practically through depositions.
Ruling
The court held that Spectrum did not need to answer Interrogatory 5. It denied defendants’ motion at ECF No. 229. The opinion is a discovery ruling and does not decide the underlying trade-secret dispute.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.