Medidata Solutions, Inc. v. Veeva Systems Inc.
- Jed Rakoff
- 1:17-cv-00589
- U.S. District Court · Southern District of New York
- 3
In Medidata v. Veeva, Judge Schofield denied Medidata’s motion to exclude expert George Hunnewell’s testimony about clinical-trial software and markets.
Medidata Solutions, Inc. and Veeva Systems Inc.; the ruling determined that portions of George Hunnewell’s expert testimony would not be excluded at this stage.
What happened
In Medidata Solutions, Inc. v. Veeva Systems Inc., Medidata asked the court to exclude portions of George Hunnewell’s expert report about clinical-trial software and the markets for that software. Medidata argued that Hunnewell lacked relevant expertise, used unreliable methods, and would not help the jury.
The court rejected those arguments. It found that Hunnewell’s industry experience and use of public information could support expert testimony about the clinical-trial software field, including whether information Medidata claimed as a trade secret had been made public. The court also found that combining industry reports, websites, and personal experience into a qualitative analysis was an acceptable method.
Judge Schofield denied Medidata’s motion in limine and directed the clerk to close the motion. The opinion does not decide the underlying trade-secret dispute.
The detailed version
- Medidata Solutions, Inc. v. Veeva Systems Inc. · No. 1:17-cv-00589
- Jed Rakoff
- Feb. 24, 2022
Background
Medidata moved to exclude portions of George Hunnewell’s expert report. The report described electronic data capture and clinical trial management system software, identified typical features of that software, and discussed the markets for it. Medidata argued that Hunnewell lacked relevant expertise, did not use a reliable methodology, and would not provide testimony helpful to the jury. Veeva opposed the motion.
Legal standard
Federal Rule of Evidence 702 governs expert testimony. The court explained that it must act as a gatekeeper by determining whether an expert is qualified, whether the opinion rests on reliable data and methods, and whether the testimony will help the factfinder.
Court’s analysis
The court found that both parties recognized Hunnewell’s significant experience in the clinical-trial software industry. It concluded that industry-specific experience, combined with publicly available information about electronic data capture and clinical trial management system products, can support expert testimony about industry practices and characteristics.
The court rejected Medidata’s argument that Hunnewell’s opinions were irrelevant because they did not connect certain public information to particular trade secrets. The testimony could assist the jury in considering whether information Medidata claimed as a trade secret had been made public. The court also explained that any overlap with lay-witness testimony did not make the expert testimony irrelevant: lay witnesses testify from personal knowledge, while Hunnewell was offered to testify about the clinical-trial software field as a whole.
The court also rejected Medidata’s challenge to Hunnewell’s methodology. His report relied on industry reports, websites, and his own experience to analyze the characteristics and market for clinical-trial software. The court held that bringing together information from many sources and synthesizing it into a qualitative analysis was an acceptable method for expert testimony.
Disposition
Judge Lorna G. Schofield denied Medidata’s motion in limine, identified as Medidata MIL 2. The clerk was directed to close the motion at Docket No. 420. This order addressed the admissibility of expert testimony and did not resolve the underlying dispute.
Note on the supplied metadata
The supplied case information identifies Jed Rakoff as the judge, but the opinion text identifies Lorna G. Schofield as the district judge. This summary follows the judge named in the opinion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.