Medidata Solutions, Inc. v. Veeva Systems Inc.

Background

Veeva moved in limine, meaning it asked the court to decide before trial what evidence or theories could be presented to the jury. Veeva sought to preclude Medidata from introducing factual theories of alleged trade-secret misappropriation that were not disclosed in Medidata’s response to Veeva’s Interrogatory No. 15 or in the expert report of Jim Davies.

Veeva’s contention interrogatory asked Medidata to identify the factual conduct that allegedly constituted misappropriation and each disclosure to, or access by, Veeva of each trade secret. Medidata’s response described alleged misappropriation, disclosure, and access, referred to specific documents, and incorporated the Davies Report by reference.

Ruling

The court explained that contention interrogatories help narrow and clarify disputed issues before summary judgment or trial. It treated the responses as judicial admissions—statements in litigation that generally prevent a party from later asserting positions omitted from its answers. The court concluded that excluding undisclosed factual theories was appropriate to clarify the issues for the trial jury.

The court also addressed Veeva’s argument concerning thousands of documents Medidata identified in responses to Interrogatory Nos. 7 and 18. The court stated that those arguments concerned possible jury confusion about whether a trade secret existed and were addressed in separate orders. Because those documents were excluded in separate orders for failing to specify a trade secret in the first instance, they could not be introduced as evidence of misappropriation in support of theories set out in the Interrogatory No. 15 response or the Davies Report.

Disposition

Veeva’s motion, identified as Veeva MIL 2, was granted. At trial, Medidata may not introduce factual theories of misappropriation that are not set forth in its Interrogatory No. 15 response or the Davies Report. The Clerk of Court was directed to close the motion at Docket No. 471.