Nextdoor.com, Inc. v. Abhyanker

Filing 76

ORDER RESETTING CMC for 6/6/13 at 1:30 p.m. Case Management Statement due by 5/30/2013. Case Management Conference set for 6/6/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 5/6/13. (bpf, COURT STAFF) (Filed on 5/6/2013)

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LAURENCE F. PULGRAM (CSB No. 115163)
[e-mail]
JENNIFER L. KELLY (CSB No. 193416)
[e-mail]
CLIFFORD C. WEBB (CSB NO. 260885)
[e-mail]
FENWICK & WEST LLP
555 California Street
San Francisco, CA 94104
Telephone:
415.875.2300
Facsimile:
415.281.1350
Attorneys for Plaintiff and Counterdefendant
NEXTDOOR.COM, INC. and Counterdefendant
PRAKASH JANAKIRAMAN
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

SAN FRANCISCO

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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NEXTDOOR.COM, INC., a Delaware
corporation,
Plaintiff,

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RAJ ABHYANKER, an individual,
Defendant.
RAJ ABHYANKER, an individual,

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JOINT CASE MANAGEMENT
STATEMENT

v.

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Case No.: 3:12-cv-05667-EMC

Counterclaimant,
v.
NEXTDOOR.COM, INC., a Delaware
corporation; PRAKASH JANAKIRAMAN, an
individual; BENCHMARK CAPITAL
PARTNERS, L.P., a Delaware limited
partnership; BENCHMARK CAPITAL
MANAGEMENT CO. LLC, a Delaware limited
liability company; SANDEEP SOOD, an
individual; MONSOON ENTERPRISES, INC., a
California corporation, and DOES 1-50,
inclusive,
Counterdefendants.
JOINT CMC STATEMENT

Case No. 3:12-cv-05667-EMC

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Pursuant to Civ. L.R. 16-9 and the Court’s Standing Order, the below-signing parties

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respectfully submit the following Joint Case Management Statement.1
Defendant and Counterclaimant Abhyanker notes that there are two pending motions

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scheduled to be heard on June 6, 2013 and that Counterdefendants Benchmark Capital Partners,

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L.P. and Benchmark Capital Management Co., LLC remain to be served. To the extent the Court

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is inclined, Abhyanker respectfully submits that it would be more efficient and fruitful to continue

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the Case Management Conference to June 6, 2013 or shortly thereafter, which would allow the

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motions to be decided prior to the CMC and would allow for the Benchmark entities to be served,

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appear, and contribute to the matters required to be discussed at the CMC.

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1.

The Declaratory Judgment Complaint (“DJ Complaint”) filed by Plaintiff Nextdoor.com,

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F ENWICK & W EST LLP

Jurisdiction and Service

Inc. (“Nextdoor.com”) is within the Court’s federal question jurisdiction pursuant to 28 U.S.C. §§

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1331, 1338, and 1367. Dkt. 1. Venue is proper in this District pursuant to 28 U.S.C. § 1291.

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Nextdoor.com, Inc. has completed service of the DJ Complaint, and no parties have raised any

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objection to venue or personal jurisdiction.
Defendant and Counterclaimant Abhyanker submits that this Court has supplemental

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jurisdiction pursuant to 28 U.S.C. § 1367 over his counterclaim for trade secret misappropriation.

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Counterdefendants Benchmark Capital Partners, L.P. and Benchmark Capital Management Co.,

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LLC have not yet been served with Abhyanker’s counterclaim. Abhyanker is waiting for the

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Court to issue Summonses for Counterdefendants Benchmark Capital Partners, L.P. and

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Benchmark Capital Management Co., LLC and will serve them shortly thereafter.

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2.

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Facts
Counterdefendants’ Statement of Facts. Abhyanker alleges that he founded a company

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called Fatdoor (“Fatdoor”) in late 2006 to pursue a neighborhood-based social networking

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business. Fatdoor operated a beta-website for this business at www.fatdoor.com for a short

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period of time before shutting down and eventually being acquired by Google (after changing its

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Counterdefendants Benchmark Capital Partners, L.P. and Benchmark Capital Management Co. LLC had not been
served as of the filing of this statement and do not join in it.
JOINT CMC STATEMENT

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name and business model multiple times). In relation to this Fatdoor business, Abhyanker

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applied for trademarks for FATDOOR, FATDOOR GET TO KNOW YOUR NEIGHBORS, and

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GET TO KNOW YOUR NEIGHBORS. Abhyanker allegedly made attempts to obtain the

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domain name www.nextdoor.com in 2006 but was unable to do so. Fatdoor never launched any

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website using the name Nextdoor, and Abhyanker did not launch a website using the Nextdoor

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name until 2012.

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Independently of Abhyanker, Plaintiff and Counterdefendant Nextdoor.com, along with

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its co-founder Counterdefendant Prakash Janakiraman (“Janakiraman”), developed the concept

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for an online social network designed to help neighbors connect in late 2010. In January of 2011,

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Nextdoor.com applied for a trademark in the NEXTDOOR mark. Nextdoor.com and

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ATTORNEYS AT LAW

they obtained the domain www.nextdoor.com to use for this website, and in February of 2011,

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F ENWICK & W EST LLP

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Janakiraman had no knowledge of Abhyanker’s alleged plans for a social network to be called

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Nextdoor or his previous attempts to obtain the domain at this time.

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In his Amended Counterclaim, Abhyanker alleges that he, independent of his company

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Fatdoor, developed and owns various trade secrets related to an online social network to be called

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Nextdoor. Abhyanker alleges that he disclosed those secrets to Counterdefendant Sandeep Sood

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while he was a contractor working for Abhyanker in 2006 and 2007. Abhyanker also alleges that

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he disclosed his Nextdoor-related trade secrets to Counterdefendant Benchmark Capital in 2007
in an effort to obtain funding for his Fatdoor entity. Abhyanker contends that both Sood and
Benchmark Capital then disclosed these trade secrets to Nextdoor.com and Janakiraman, and that
they used the secrets in developing their business. Counterdefendants deny this.
Based on this alleged misappropriation, Abhyanker filed an action for trade secret
misappropriation and various related causes of action in California Superior Court for the County
of Santa Clara (the “State Court Action”) in December 2011 against Nextdoor.com, Janakiraman,

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two Benchmark Capital entities, and others. Facing demurrers in the State Court Action arguing,
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inter alia, that Abhyanker had no standing or viable trade secrets, Abhyanker filed two
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oppositions to Nextdoor.com’s application to register the NEXTDOOR mark in the Trademark
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JOINT CMC STATEMENT

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Trial and Appeal Board in early 2012. Those oppositions argued that Nextdoor.com’s mark

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infringed the FATDOOR, FATDOOR GET TO KNOW YOUR NEIGHBOR, GET TO KNOW

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YOUR NEIGHBOR, and NEXTDOOR marks all allegedly owned by Abhyanker. After filing

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these oppositions, Abhyanker dismissed the State Court Action before the court could rule on the

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defendants’ demurrers.

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Around this same time in February 2012, Nextdoor.com alleges that Abhyanker, for

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leverage in litigation against Nextdoor.com, registered the www.nextdoor.cm domain name and

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began publicly using the NEXTDOOR mark for the first time. Based on these actions and

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Abhyanker’s allegations of infringement, Nextdoor.com filed this action for a declaration of non-

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Counterclaim again making his allegations of trade secret misappropriation now against

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infringement and cybersquatting. Abhyanker has filed a Counterclaim and an Amended

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F ENWICK & W EST LLP

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Nextdoor.com, Janakiraman, Sandeep Sood (“Sood”), Sood’s company Monsoon Enterprises,

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Inc. (“Monsoon”), Benchmark Capital Partners, L.P., and Benchmark Capital Management Co.

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LLC.

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Defendant and Counterclaimant Abhyanker’s Statement of Facts. Nextdoor.com,

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Benchmark Capital, and the individuals associated with them have a pattern and practice of

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building companies based on stolen information. This case is one example of their common

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pattern and practice. Around September 2006, Abhyanker developed the concept of a private
online neighborhood social network for inventors to be called LegalForce, and a separate spin off
idea using the same code base called Nextdoor. In connection with his LegalForce and Nextdoor
concept, Abhyanker developed and owned trade secret information, a list of which is described in
Abhyanker’s counterclaim. Abhyanker disclosed the trade secrets to Counterdefendants Sandeep
Sood, Monsoon Enterprises, and the Benchmark entities under obligations of confidentiality.
Despite their obligations of confidentiality, Sandeep Sood, Monsoon, and Benchmark disclosed

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the trade secrets to Nextdoor.com and Prakash Janakiraman. Despite knowing that the trade
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secret information was improperly acquired (and encouraging the improper disclosure),
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JOINT CMC STATEMENT

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Nextdoor.com and Janakiraman publicly launched the www.nextdoor.com online neighborhood

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social network that uses and was built on the trade secrets misappropriated from Abhyanker.

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Legal Issues

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At this point in the case, Nextdoor.com, Prakash Janakiraman, and Monsoon submit that

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the manner in which the case will proceed depends substantially on the resolution of the

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following legal issues:

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

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networking.


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ATTORNEYS AT LAW

F ENWICK & W EST LLP

Whether Abhyanker’s use of the NEXTDOOR mark creates a likelihood of confusion
with Nextdoor.com’s mark.

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Whether Nextdoor.com has priority of use for the NEXTDOOR mark for online social

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Whether Nextdoor’s use of its NEXTDOOR mark creates any likelihood of confusion

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between Abhyanker’s claimed FATDOOR, GET TO KNOW YOUR NEIGHBORS, or

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FATDOOR GET TO KNOW YOUR NEIGHBORS marks.

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YOUR NEIGHBORS, or FATDOOR GET TO KNOW YOUR NEIGHBORS marks.
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Whether Abhyanker registered the www.nextdoor.cm domain in a bad faith attempt to
profit from Nextdoor.com’s NEXTDOOR mark.

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Whether Abhyanker is the owner of any of the purported trade secrets he asserts in his
Amended Counterclaim.

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Whether Abhyanker owns any rights in the NEXTDOOR, FATDOOR, GET TO KNOW

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Whether public disclosure of the “nextdoor.com” name in relation to an online

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neighborhood social network in a published patent application extinguished any trade

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secret rights in that concept Abhyanker may have had.

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Whether Monsoon and or Sood are subject to a contractual obligation of confidentiality to
Abhyanker in connection with Abhyanker’s purported trade secrets.

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Whether Monsoon and or Sood disclosed to Nextdoor.com or Janakiraman any of the

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JOINT CMC STATEMENT

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purported trade secrets Abhyanker claims to own in his Amended Counterclaim.

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Defendant and Counterclaimant Abhyanker submits that there are no “disputed points of

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law.” Abhyanker respectfully submits that the above bulleted list provided by Counterdefendants

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are not disputed points of law, but simply issues involving the application of law to facts that

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remain subject to dispute and discovery, and which need to be decided in the case.

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4.

Motions

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Counterdefendants Nextdoor.com, Janakiraman, Monsoon, and Sood have pending
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motions to dismiss Abhyanker’s Amended Counterclaim with a hearing date of June 6, 2013.
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Plaintiff and Counterdefendant Nextdoor.com also has a pending motion to strike Abhyanker’s
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ATTORNEYS AT LAW

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affirmative defenses set for hearing on that date. Abhyanker has a pending motion to disqualify
Plaintiffs’ Counsel, also set for hearing on June 6, 2013.
If their motion to dismiss is denied and Abhyanker’s misappropriation claim stays in the

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case, Nextdoor.com and Janakiraman anticipate filing a motion for summary judgment on
Abhyanker’s Amended Counterclaim. Nextdoor.com also anticipates filing a motion for
summary judgment on its affirmative claims—including that Nextdoor.com has priority of use in
the NEXTDOOR mark, that Abhyanker’s recent use of the NEXTDOOR mark is infringing, that
Abhyanker does not own any rights in the FATDOOR, GET TO KNOW YOUR NEIGHBORS,

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or FATDOOR GET TO KNOW YOUR NEIGHBORS marks, that Nextdoor’s mark does not

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infringe those marks, and that Abhyanker engaged in cybersquatting in registering and using the

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www.nextdoor.cm domain.

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If their motion to dismiss is denied and Abhyanker’ misappropriation claim stays in the

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case, Monsoon Enterprises, Inc. and Sood anticipate filing a motion for summary judgment on

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Abhyanker’s Amended Counterclaim.
Defendant and Counterclaimant Abhyanker anticipates filing one or more motions for

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summary judgment directed at Nextdoor.com’s claims and/or Abhyanker’s counterclaim.

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5.

Amendment of Pleadings

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JOINT CMC STATEMENT

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Plaintiff and Counterdefendant Nextdoor.com, Inc. does not currently plan to amend its

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DJ Complaint, but may seek leave to do so depending on the fact learned through discovery.
At this time, Defendant and Counterclaimant Abhyanker does not expect to amend its

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pleading. However, Abhyanker notes that Counterdefendants Nextdoor.com, Prakash

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Janakiraman, and Monsoon have filed motions to dismiss. In the event the motions are granted,

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Abhyanker would respectfully ask the Court for leave to amend. In addition, Abhyanker may

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seek to amend its pleading depending on facts learned through discovery.

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6.

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The parties have taken reasonable steps to preserve evidence.
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Disclosures
The parties propose exchanging initial disclosures two weeks after the final

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

Evidence Preservation

counterdefendant is served. Presently, counterdefendants Benchmark Capital Management, L.P

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and Benchmark Capital Management Co. LLC remain to be served with the Amended

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Counterclaim. Abhyanker is waiting for the Court to issue Summonses for the two remaining

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Counterdefendants and will serve them shortly thereafter.

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Discovery
Nextdoor.com served an initial set of requests for production and interrogatories on

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Defendant Abhyanker on April 24, 2013. Responses to those requests are due on May 28, 2013.

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No other discovery has been taken.

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The parties anticipate entering into a stipulated protective order.

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Defendant and Counterclaimant Abhyanker anticipates serving written discovery in May

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2013 and notices of depositions thereafter. At this time, Abhyanker does not anticipate

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modifications to the discovery rules, but reserves the right to request such modifications if

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appropriate moving forward. As detailed in Section 17 below, Abhyanker respectfully submits

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that it is premature to schedule discovery cutoffs because (i) Counterdefendants Benchmark

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Capital Partners, L.P. and Benchmark Capital Management Co., LLC remain to be served and

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have not had an opportunity to provide input into a discovery schedule and (ii) the discovery

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JOINT CMC STATEMENT

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schedule will be affected substantially by the outcome of the pending motions to dismiss, which

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will determine whether Abhyanker’s counterclaim for trade secret misappropriation remains in

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the case.

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Not applicable.

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Class Actions

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Related Cases
There are co-pending oppositions to Nextdoor.com’s registration of its NEXTDOOR mark

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in the Trademark Trial and Appeal Board (“TTAB”) filed by Abhyanker (Opposition Nos.

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31203462 and 91203762). Those opposition proceedings have been suspended pending the
outcome of this case.

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F ENWICK & W EST LLP

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Relief
Nextdoor.com’s DJ Complaint against Abhyanker seeks a declaration that Nextdoor.com

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is lawfully using its NEXTDOOR mark and not infringing any trademark rights held by

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Abhyanker; that Nextdoor.com has priority of use of the NEXTDOOR mark in the field of online

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social networking; and that there is no likelihood of confusion between Nextdoor.com’s use of its

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NEXTDOOR mark and any purported trademark rights of Abhyanker with respect to the terms

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“fatdoor” or “fatdoor get to know your neighbors.” Nextdoor.com also seeks transfer of the

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www.nextdoor.cm domain name; an award of statutory damages up to $100,000 for Abhyanker’s

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registration and use of that domain; an award of Abhyanker’s profits from his infringing conduct;

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an order enjoining Abhyanker from use of the NEXTDOOR mark, or any colorable imitation
thereof, in the field of online social networking; and Nextdoor.com’s costs and attorneys’ fees.
Monsoon and Sood seek to have the Abhyanker’s Amended Counterclaim dismissed with
prejudice, that Abhyanker take nothing by way of his counterclaim and for an award of Monsoon
and Sood’s costs and attorneys’ fees.
Defendant and Counterclaimant Abhyanker seeks the following relief: (i) that
Nextdoor.com take nothing by its Complaint; (ii) that Nextdoor.com’s Complaint be dismissed
with prejudice; (iii) that Abhyanker be awarded his costs of suit and attorneys’ fees; (iv) that all

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JOINT CMC STATEMENT

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Counterdefendants be preliminarily and permanently enjoined from further disclosing or using

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Abhyanker’s LegalForce/Nextdoor trade secrets, as well as Abhyanker’s confidential and

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proprietary non-trade secret information, including, but not limited to, the nextdoor.com website

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and domain name; (v) that Counterdefendant be enjoined from the practice of hiring and/or

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placing Entrepreneurs in Residence (EIR) that the fund intends to invest in, and which have not

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yet come up with a public business plan for their venture, to listen in on or participate in any way

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in meetings involving other entrepreneurs pitching ideas to the fund in an area of technology

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specialization that the EIRs intend to start a company of their own within and has not thought of

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or publicly released; (vi) that the Court order Nextdoor.com to transfer the nextdoor.com domain

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nextdoor.com domain name, to change the registrar of record for the nextdoor.com domain name

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name to Abhyanker and order and direct VeriSign, Inc., the domain name registry for the

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F ENWICK & W EST LLP

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to a registrar selected by Abhyanker; (vii) on his trade secret misappropriation claim, that

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Abhyanker recover damages for his actual loss caused by the misappropriation; (viii) on his trade

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secret misappropriation claim, that Abhyanker recover for the unjust enrichment caused by

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Counterdefendants’ misappropriation; (ix) on his trade secret misappropriation claim, that

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Abhyanker recover a reasonable royalty to the extent neither damages nor unjust enrichment are

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provable; (x) on his trade secret misappropriation claim, that Abhyanker recover exemplary

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damages; and (xi) that the Court order such further relief as it deems just and proper.

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Settlement and ADR
There have been limited settlement discussions to date. The parties are in discussions to

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determine whether they can agree to mediation through the Court's ADR unit. The parties

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submitted a Notice of Need for ADR Phone Conference on April 19, 2013( Dkt. 61) and such

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conference has been scheduled for May 6, 2013.

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Defendant and Counterclaimant Abhyanker is agreeable to mediation. In addition,

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Abhyanker believes that any decisions regarding ADR should involve Counterdefendants

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Benchmark Capital Partners, L.P. and Benchmark Capital Management Co., LLC. Abhyanker is

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waiting for the Court to issue Summonses for these Counterdefendants and will serve them

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JOINT CMC STATEMENT

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shortly thereafter.

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Consent to Magistrate Judge

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Nextdoor.com, Prakash Janakiraman, and Monsoon do not consent to a Magistrate Judge.

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Defendant and Counterclaimant Abhyanker consents to have a magistrate judge conduct

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all further proceedings, including trial and entry of judgment.

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14.

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Other References
No other references are necessary.

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Narrowing of Issues
As discussed above, Nextdoor.com, Prakash Janakiraman, and Monsoon believe the issues

can be narrowed through resolution of counterdefendants’ motions to dismiss and strike, and/or

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motions for summary judgment.

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F ENWICK & W EST LLP

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At this time, Defendant and counterclaimant Abhyanker does not believe that there are

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issues that can be narrowed by agreement or motion, has no suggestions to expedite the

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presentation of evidence at trial, and does not request to bifurcate any issues, claims, or defenses.

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16.

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Expedited Schedule
The parties do not believe that this case is suitable for an expedited schedule.

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Scheduling
Subject to the Court’s calendar, Nextdoor.com, Prakash Janakiraman, and Monsoon

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propose to set April 14, 2014 as a date to start trial; in accordance therewith, the parties propose

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to set the following pretrial schedule:

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

Initial Disclosures:

Two weeks after service of Benchmark entities

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

Initial CMC

May 9, 2013

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

Last day to amend pleadings:

August 1, 2013

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

Fact Discovery Cutoff:

October 1, 2013

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

Opening expert reports:

November 5, 2013

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

Supplemental/Rebuttal

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Expert Reports:

December 10, 2013

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JOINT CMC STATEMENT

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

Expert Discovery Cutoff:

December 20, 2013

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

Last day to file dispositive motions:

January 13, 2014

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Dispositive Motion hearing date:

TBD

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

Final pretrial conference:

March 18, 2014

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

Trial:

April 14, 2014

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Defendant and Counterclaimant Abhyanker believes that it is premature to schedule a trial

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date or discovery cutoffs because (i) Counterdefendants Benchmark Capital Partners, L.P. and

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Benchmark Capital Management Co., LLC remain to be served and have not had an opportunity

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to provide input into a schedule of dates and (ii) the schedule will be affected substantially by the

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counterclaim for trade secret misappropriation remains in the case.

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ATTORNEYS AT LAW

outcome of the pending motions to dismiss, which will determine whether Abhyanker’s

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F ENWICK & W EST LLP

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18.

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Trial
All parties have consented to a trial by jury. Based on the current knowledge of all

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parties, it is believed that the case should last between 8 to 10 days of trial based on the Court’s

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current published trial scheduling procedures.

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19.

Disclosure of Non-Party Interested Entities

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All parties have made the required disclosures.

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Plaintiff and Counterdefendant Nextdoor.com has no parent corporation and no publicly

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held corporation is known to own 10% or more of Nextdoor.com’s stock.

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Counterdefendant Monsoon has no parent corporation and no publicly held corporation is
known to own 10% or more of Monsoon’s stock.

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Pursuant to Civil Local Rule 3-16, Defendant and Counterclaimant Abhyanker certifies

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that, as of this date, other than the named party, there is no such interest to report.

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20.

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Other Matters
There are no other matters the Court should address at this Case Management Conference.

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JOINT CMC STATEMENT

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Dated: May 2, 2013

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FENWICK & WEST LLP
By: /s/ Jennifer L. Kelly
Jennifer L. Kelly

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Attorneys for Plaintiff and Counterdefendant
NEXTDOOR.COM, INC. and Counterdefendant
PRAKASH JANAKIRAMAN

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LEGALFORCE RAJ ABHYANKER, P.C.

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By: /s/ Bruno W. Tarabichi
Bruno W. Tarabichi

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Attorneys for Defendant and Counterclaimant
RAJ ABHYANKER

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SAN FRANCISCO

ROYSE LAW FIRM, PC

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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By: /s/ Harpreet S. Walia
Harpreet S. Walia

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Attorneys for Counterdefendants SANDEEP
SOOD and MONSOON ENTERPRISES, INC.

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JOINT CMC STATEMENT

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ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1

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I, Jennifer L. Kelly, am the ECF User whose identification and password are being used to
file this ADR CERTIFICATION BY PARTIES AND COUNSEL. In compliance with Civil
Local Rule 5-1, I hereby attest that all signatories have concurred in this filing.
Dated:

May 2, 2013

/s/ Jennifer L. Kelly
Jennifer L. Kelly

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ER

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R NIA

hen

rd M. C

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dwa
Judge E

ERED

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SAN FRANCISCO

ATTORNEYS AT LAW

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O ORD
IT IS S

United States District Judge

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F ENWICK & W EST LLP

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RT
U
O

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NO

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S DISTRICT
TE
_________________________
C
TA
Edward M. Chen

A

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S

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IT IS SO ORDERED that the case management is reset for 6/6/13 at 1:30 p.m. A joint
CMC Statement shall be filed by 5/30/13.

UNIT
ED

8

N

F
D IS T IC T O
R

C

18
19
20
21
22
23
24
25
26
27
28
JOINT CMC STATEMENT

12

Case No. 3:12-cv-05667-EMC