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 Solutions v. Veeva Systems, Judge Schofield denied Veeva’s motion to exclude unjust-enrichment evidence from the jury.
Medidata Solutions, Inc. and Veeva Systems, Inc.; the ruling concerns what evidence the jury may hear and how the jury may address an unjust-enrichment damages amount at trial.
What happened
In Medidata Solutions, Inc. v. Veeva Systems Inc., Veeva asked the court to keep the jury from hearing evidence related only to unjust enrichment, including avoided costs and disgorgement of profits. Medidata opposed the request.
Veeva argued that unjust enrichment is an equitable remedy decided by a judge, making evidence about it irrelevant to the jury. The court rejected that premise because the Defend Trade Secrets Act describes unjust enrichment as a form of damages and courts have allowed juries to award such damages.
Judge Lorna G. Schofield denied Veeva’s motion in limine. The parties may present the jury with evidence relating solely to unjust enrichment, and the court will ask the jury for its view of any unjust-enrichment amount before deciding whether that view is advisory. The parties must also file letters about whether unjust enrichment under California law should be decided by the court or jury.
The detailed version
- Medidata Solutions, Inc. v. Veeva Systems Inc. · No. 1:17-cv-00589
- Jed Rakoff
- Feb. 25, 2022
Background Veeva moved in limine to exclude from the jury evidence relating solely to unjust enrichment. Medidata opposed the motion. Medidata’s damages expert, David Hall, offered opinions based on two unjust-enrichment theories: avoided costs and disgorgement of profits.
Arguments and legal framework Veeva argued that unjust enrichment is an equitable remedy that must be decided by the court rather than the jury. The court rejected that argument as based on the incorrect premise that the jury would not address unjust enrichment.
The court relied on the Defend Trade Secrets Act, which describes damages for a defendant’s unjust enrichment as “damages,” alongside damages for the plaintiff’s actual loss and damages measured by a reasonable royalty. The court found no compelling reason in that statutory language to divide responsibility for damages between the judge and jury. It also cited decisions holding that juries determined monetary awards for avoided costs under the federal Defend Trade Secrets Act or state trade-secret laws derived from the Uniform Trade Secrets Act.
The court found the authority cited by Veeva unpersuasive. That decision was not binding on the court, treated the judge-versus-jury issue as an aside, did not discuss the relevant federal statute, and involved a claim based on Texas law.
Ruling The court denied Veeva MIL 8. The parties may present the jury with evidence relating to unjust enrichment at trial. Because the court stated that the issue appeared to be one of first impression in the circuit, it will seek the jury’s view of the amount of any unjust-enrichment award on the verdict sheet and later decide whether that view is merely advisory under Federal Rule of Civil Procedure 39(c). The parties were ordered to separately file letters, each no longer than three pages, addressing whether unjust enrichment under the California Uniform Trade Secret Act should be determined by the court or the jury.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.