Elan Microelectronics Corporation v. Apple, Inc.

Filing 249

MOTION to Compel Apple, Inc. to Produce Testing Tool (Public Version) filed by Elan Microelectronics Corporation. (DeBruine, Sean) (Filed on 6/7/2011)

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1 2 3 4 5 6 7 8 9 10 11 YITAI HU (SBN 248085) yitai.hu@alston.com SEAN P. DEBRUINE (SBN 168071) sean.debruine@alston.com ELIZABETH H. RADER (SBN 184963) elizabeth.rader@alston.com JANE HAN BU (SBN 240081) jane.bu@alston.com JENNIFER LIU (SBN 268990) celine.liu@alston.com PALANI P. RATHINASAMY (SBN 269852) palani.rathinasamy@alston.com ALSTON & BIRD LLP 275 Middlefield Road, Suite 150 Menlo Park, CA 94025-4008 Telephone: 650-838-2000 Facsimile: 650-838-2001 Attorneys for Plaintiff and Counterdefendant ELAN MICROELECTRONICS CORPORATION 12 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO DIVISION 16 17 18 ELAN MICROELECTRONICS CORPORATION, Plaintiff and Counterdefendant, 19 20 21 22 v. APPLE, INC., Defendant and Counterplaintiff. 23 24 AND RELATED COUNTERCLAIMS 25 Case No. 5:09-cv-01531 RS (PSG) PLAINTIFF ELAN MICROELECTRONICS CORPORATION’S NOTICE OF MOTION AND MOTION TO COMPEL APPLE, INC. TO PRODUCE TESTING TOOL Date: June 7, 2011 Time: 2:00 p.m. Courtroom 5 Hon. Paul S. Grewal PUBLIC VERSION 26 27 28 ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL Case No. 5:09-cv-01531 RS (PSG) NOTICE OF MOTION AND MOTION 1 2 TO APPLE, INC. AND ITS ATTORNEYS OF RECORD: 3 PLEASE TAKE NOTICE that on June 7, 2011, at 2:00 p.m., in Courtroom 5, located at 4 280 South First Street, Fifth Floor, San Jose, California, Plaintiff Elan Microelectronics 5 Corporation (“Elan”) will and hereby does move this Court, pursuant to L.R. 37-1(a) and Fed. R. 6 Civ. P. 37(a)(1) and 37(a)(4), to Compel defendant Apple, Inc. (“Apple”) to produce copies of the test tool application for use with each of the accused Apple products. 7 8 9 As its basis for this motion, as more fully set forth in the following Memorandum of Points and Authorities, Elan states that Apple has developed an internal testing program it calls the which 10 and the by the in the 11 accused products. This program is called for by Elan’s document requests served in August 2009, 12 yet Apple has not produced that testing tool to Elan. Apple has flatly refused to produce a copy of 13 the program, and refuses to permit inspection by Elan’s expert witness without undue condition. 14 Apple has no justification for the limits it seeks to impose on the production of this highly relevant 15 discovery. Rather, Apple’s action (or more appropriately inaction) demonstrates that the Court 16 should order the immediate production of a copy or copies of the testing program to enable the 17 analysis of all of the accused products. At a minimum, the Court must order Apple to provide 18 unfettered access to the full range of programs, in both Apple counsel’s Boston and Redwood 19 Shores offices within 48 hours of a request to inspect, with Apple counsel’s supervision limited to 20 the minimum necessary to prevent Elan’s counsel or expert from absconding with a copy of the 21 program. 22 This motion is based upon this Notice of Motion and Memorandum of Points and 23 Authorities, the Declarations of Palani P. Rathinasamy (“Rathinasamy Decl.”) and Sean P. 24 DeBruine (“DeBruine Decl.”), in Support of the Motion to Compel, and on such other argument 25 and evidence as may be presented to the Court at or prior to the hearing on this motion. 26 27 28 ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 1 Case No. 5:09-cv-01531 RS (PSG) 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 I. 3 STATEMENT OF MATERIAL FACTS Elan filed its Complaint in this matter on April 7, 2009, alleging that Apple’s products 4 5 including multi-touch touchpads and touchscreens infringe, inter alia, U. S. Patent No. 5,825,352 6 (the 352 patent) (Dkt. No. 1). The accused Apple products include laptop computers with 7 touchpad input devices, other devices with touchscreen input such as the iPhone and iPod Touch 8 product, and other peripheral touchpads. Rathinasamy Decl., ¶ 2. On August 6, 2009, Elan served 9 Apple its First Set of Request for Productions [Nos. 1-65]. Request for Production No. 20 and 21 10 requests that Apple produce: REQUEST FOR PRODUCTION NO. 20: All documents and things concerning the design, research, development, and/or testing of Apple’s Products. 11 12 13 REQUEST FOR PRODUCTION NO. 21: Documents concerning or relating to the structure, function, or operation of the Apple Product(s), including, but not limited to specifications, data sheets, drawings, diagrams, circuits, schematics, notebooks, project reports, workbooks, lab books, notes, code, memoranda, test plans, test results, CAD, simulation files, and marketing and sales materials. 14 15 16 17 (Rathinasamy Decl., Ex. A at 8). On September 8, 2009, Apple responded to Elan’s request 18 stating that it would produce “non-privileged documents sufficient to show the design, 19 development, and/or testing of the relevant functionalities in the accused Apple products . . . .” (id., 20 Ex. B at 14-15). Despite this agreement to produce documents regarding the “testing of the 21 relevant functionalities” Apple did not produce the 22 . However, during the Hearing in the parties’ parallel case in the United States International 23 Trade Commission (“ITC”) in February 2011, one of Apple witness testified of the existence of 24 the 25 Apple’s witness explained that the testing tool used by Apple tool1 (Rathinasamy Decl., Ex. C [Westerman Tr.] at 380:11-16). and 26 27 28 1 The discovery cut off in the ITC investigation was November 15, 2010, with a November 10 deadline for Motion to compel. Apple produced a user manual relating to the on November 12, 2010 along with more than 250,000 pages of other documents (Rathinsamy Decl., ¶ 5). ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 2 Case No. 5:09-cv-01531 RS (PSG) of the 1 with the ability for (id.). Although Apple was 2 in possession of the testing tool, and although that tool was specifically requested by Elan but not 3 produced, Apple emphasized in its post-hearing brief to the ITC that Elan’s expert witness Mr. 4 Dezmelyk “did not base his opinion on any actual 5 (Rathinasamy Decl., Ex. D [Apple’s Post-Hearing Brief] at 33) (emphasis added). In other words, 6 Apple argued that Elan did not prove its case because it did not have the very evidence Apple had 7 withheld from production (id. at 50). After the Hearing at the ITC, on March 17, 2011 and again on March 26, 2011, Elan 8 9 to confirm infringement” specifically requested that Apple immediately produce a working copy of the testing tool described by Apple’s 30(b)(6) witness as well as “any other software or 10 11 hardware tools that test, demonstrate or capture the function of the accused products . . . .” 12 (Rathinasamy Decl., Ex. E [03/17/2011 Letter from S. DeBruine to S. Mehta]; Ex. F [03/26/2011 13 S. DeBruine e-mail to S. Mehta]). Apple responded on April 4, 2011 stating that: 14 As you know, the is a working tool and not simply something we can produce on paper or on a hard drive, especially given its highly proprietary nature. Given your request, however, Apple is willing to consider making the tool available for live testing by Elan's outside counsel or Mr. Dezmelyk, subject to the protective order… 15 16 17 (Rathinasamy Decl., Ex. G [04/04/2011 S. Mehta e-mail to S. DeBruine] at 1). 18 19 20 21 22 During an April 5, 2011 meet and confer call, Elan understood Apple to state that it would only produce the Highly Confidential Attorneys Eyes Only – Source Code in the Amended Protective Order (Rathinasamy Decl., ¶ 11). In an effort to expedite access to the 25 and avoid bringing a discovery motion to the Court, Elan agreed that it would make a preliminary inspection of the 23 24 tool for inspection subject to the provisions for and then further discuss an inspection procedure (Rathinasamy Decl., Ex. H [4/12/2011 P. Rathinasamy e-mail to D. Walter]). On April 12, 2011 Elan proposed to Apple that: 26 27 28 As such, for a starting point, we propose to have an initial inspection of the tool, at the facility of Apple's choice, subject to the source code provision of the protective order, for our outside counsel and/or expert to simply get familiar with the operation of the tool. After the initial inspection, the parties then can meet and confer to agree upon the contour ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 3 Case No. 5:09-cv-01531 RS (PSG) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and details of the live testing and the related document production resulted from such tests. Please let us know by Friday, April 15, whether you are agreeable to this proposal. (id.). On April 15, 2011 Apple responded that it would make the tool available for an initial inspection but would restrict the inspection “to outside counsel only, and not expert witnesses” (Rathinasamy Decl., Ex. I [4/15/2011 D. Walter e-mail to P. Rathinasamy]). Elan’s outside counsel thereafter requested an inspection of the tool to get familiar with its operation, (Rathinasamy Decl., Ex. J [5/2/2011 P. Rathinasamy to D. Walter]), and inspected the tool on May 11, 2011 (Rathinasamy Decl. at ¶ 15). Contrary to counsel’s representation that the tool “could not be produced on a hard drive” the test tool is an application program loaded on the hard drive of a MacBook laptop computer (id.). It ran on that computer and the from the computer’s (id.). During the inspection on May 11, Apple only produced the version of the tool for the MacBook Pro product. It did not have the tool available for use with any of the other Accused Products, such as the iPhone or iPad (Rathinasamy Decl., at ¶ 15; DeBruine Decl., at ¶ 2). At the inspection, Elan’s counsel specifically asked Apple’s counsel about inspecting the tool to analyze the other Accused Products, namely the iPhone, iPad and iPod touch products running Apple’s “iOS” operating system. Apple’s counsel supervising the inspection expressed surprise at the request and stated that counsel had not asked Apple for such a version of the tool and had never seen such a version. He stated that Apple would get back to Elan on that request (DeBruine Decl., at ¶ 3). A full week later, having heard nothing from Apple, Elan repeated its request in writing. In addition, since the deposition of Elan’s expert had been scheduled for May 24 in Apple’s counsel’s offices, Elan informed Apple that Mr. Dezmelyk would join counsel for that initial, informal inspection (Rathinasamy Decl., Ex. K [05/18/2011 P. Rathinasamy e-mail to D. Walter]). When Apple failed to respond to Elan’s request, on May 23, 2011 Elan was forced to repeat its request: “I write following-up on my emails regarding Apple’s tool and production of videos. Regarding Apple’s tool, please confirm that the tool will be made available for our inspection on Wednesday, May 25 ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 4 Case No. 5:09-cv-01531 RS (PSG) 1 at 9:30 AM for the iPhone, iPad, and MacBook products” (Rathinasamy Decl., Ex. L [5/23/2011 P. 2 Rathinasamy e-mail to D. Walter]). 3 4 Despite being on notice as of May 11 that it had failed to provide the for inspection with all Apple products, Apple responded that it could not produce the 5 tool in time for the May 25 inspection and, for the first time stated that it would not allow 6 Elan’s expert to inspect the tool absent videotaping “regardless of whether he is able to collect 7 printed data.” (Rathinasamy Decl., Ex. M [5/23/2011 D. Walter e-mail to P. Rathinasamy]). 8 Elan responded explaining that, since the 9 should be immediately produced (Rathinasamy Decl., Ex. N [5/23/2011 P. Rathinasamy e-mail Tool is not source code it 10 to D. Walter]). Elan further explained that even if it were source code, the protective order 11 allows for visual monitoring only to prevent unauthorized electronic records from being created, 12 and that videotaping would capture conversations between counsel and the expert is 13 inconsistent with the parties’ agreement regarding communications with experts (id.). 14 On May 24, Apple simply abandoned its position that the Tool is 15 “source code” subject to the heightened protections of the Amended Protective Order. 16 (Rathinasamy Decl., Ex. O [5/24/2011 D. Walter email to P. Rathinasamy]). Apple’s 17 continuing failure to even provide the tool on all version of Apple products to Elan’s counsel as 18 requested, the fact that those requests were still being ignored by Apple, its about-face on the 19 reasons for its obstruction and its unreasonable restrictions it was placing on any such 20 inspection, made it clear that the Court’s intervention was necessary. Because Elan’s expert 21 was scheduled to return to New Hampshire the following day, Elan sought the expedited 22 intervention of the Court. 23 On May 24 the parties held a telephonic discovery conference with Magistrate Judge 24 Grewal. During that telephone conference Apple’s counsel flatly, and as shown above falsely, 25 represented that Elan had never requested that the 26 available for the iOS products (DeBruine Decl., ¶ 5). Moreover, counsel misleadingly 27 represented that it would not be able to make “the full range” of the 28 for inspection the next day even if ordered (id.). Only when counsel for Elan explained that the ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 5 testing tool be made tool available Case No. 5:09-cv-01531 RS (PSG) 1 testing tool was already available on the MacBook laptop did Apple’s counsel agree that it 2 could have made that version available for Elan’s expert to inspect (id.). Because all of these 3 facts were not available to the Court, it ordered that this motion be filed and considered on 4 shortened time (Dkt. No. 208). 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Elan hereby states that it has satisfied its meet and confer obligation pursuant to L.R. 37-1(a) and Fed. R. Civ. P. 37(a)(1). II. “[P]arties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense” or “appears reasonably calculated to lead to the discovery of admissible evidence.” Fed. R. Civ. P. 26(b)(1). Therefore, it is well-established that the federal discovery rules reflect a broad and liberal approach to achieving the goal of informing parties in civil cases of all material facts prior to trial. In re Google Litig., 2011 U.S. Dist. LEXIS 9924 (N.D. Cal. Jan. 27, 2011) (Mag. J. Grewal). “This standard applies with no less force in patent cases.” Id. Further, “[f]or good cause, the court may order discovery of any matter relevant to the subject matter involved in the action.” Fed. R. Civ. P. 26(b)(1). A motion to compel is appropriate when a party provides an “incomplete disclosure, answer, or response” to a discovery request. Fed. R. Civ. P. 37(a)(3)(A) & (a)(4). Here, there is no dispute that the 24 testing tool is highly relevant to Elan’s claims, nor that Apple has refused to either produce a copy or make reasonable arrangements for Elan to inspect and test that tool. As such, an order compelling production is necessary. A. 22 23 ARGUMENT The Court Should Compel Apple to Immediately Produce Copies of the Test Tool to Elan The Tool is a test tool used by Apple employees to from and in each of the Accused Products. Production of a 25 working copy of the tool was required by Elan’s document requests served on Apple on 26 September 8, 2009 and expressly requested by Elan in March 2011 (Rathinasamy Decl., Exs. A 27 [Elan’s First Set of Request For Production [Nos. 1-65] at RFP Nos. 20-21], E [03/17/2011 S. 28 DeBruine letter to S. Mehta], F [03/26/2011 S. DeBruine e-mail to S. Mehta], P [05/24/2011 S. ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 6 Case No. 5:09-cv-01531 RS (PSG) 1 DeBruine e-mail to D. Walter]). Apple refused to produce the testing tool and instead argued that 2 the testing tool is “highly proprietary” and would be “willing to consider making the tool available 3 for live testing by Elan’s outside counsel or Mr. Dezmelyk, subject to the protective order” 4 (Rathinasamy Decl., Ex. G [4/4/2011 S. Mehta e-mail to S. DeBruine]). Under the Amended 5 Stipulated Protective Order, “source code” is entitled to additional protections. The entirety of 6 such code may only be inspected at counsel’s offices, while only portions may be printed and 7 produced, subject to producing counsel’s objections as to the amount of code printed (Dkt. No. 64 8 at 10). Documents and things other than “source code” are to be copied and produced, marked 9 with the “Confidential Outside Counsel’s Eyes Only” designation as appropriate (id. at 8-9). 10 Apple now admits that the Tool is not “Source Code” and it is 11 therefore not subject to the extra protections provided by the Protective Order (Rathinasamy Decl., 12 Ex. O [5/24/2011 D. Walter email to P. Rathinasamy]). As such, Apple has no basis whatsoever 13 for not immediately producing the copies of that tool sufficient to analyze all of the accused 14 products. There are neither technical nor confidentiality issues preventing such a production. 15 Contrary to counsel’s earlier representation, the testing tool can easily be “loaded on a hard drive” 16 (DeBruine Decl., ¶ 2). In fact, that is exactly how it is used at Apple (id.). Elan is more than 17 willing to either reimburse Apple at its cost for the computers on which the tool is loaded or to 18 provide such computers to Apple. Therefore, Apple has no basis to complain that it is too difficult 19 or burdensome to produce the tool to Elan. In re Google Litig., 2011 U.S. Dist. LEXIS at *19-20 20 (finding the defendant has not offered “concrete, particularized evidence regarding the undue 21 burden of production” of all requested data and rejecting the “generic attorney argument” 22 regarding burden of production). 23 Apple similarly cannot complain that the Protective Order is insufficient to prevent 24 dissemination of the tool. Assuming it is designated as “Confidential – Outside Counsel’s Eyes 25 Only” access will be restricted to Elan’s litigation counsel and its expert approved by Apple to 26 receive such information. Elan’s counsel and expert will be obligated to protect the confidentiality 27 of that tool, to use it only for purposes of this litigation and to destroy or return it to Apple at the 28 conclusion of the litigation (Dkt. No. 64 at 8-10). These protections are more than sufficient to ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 7 Case No. 5:09-cv-01531 RS (PSG) 1 protect the 2 U.S. Dist. LEXIS 111401, *5 (N.D. Cal. July 23, 2008) (granting plaintiff’s motion to compel 3 defendant’s source code because “there is a stipulated protective order in place which addresses 4 [defendant’s] confidentiality concerns”). See, also Perez v. State Farm Mut. Auto. Ins. Co., 2011 5 U.S. Dist. LEXIS 41009 (N.D. Cal. Apr. 11, 2011) (Mag. J. Grewal) (rejecting defendant’s basis 6 for withholding “sensitive financial information” in light of the stipulated protective order already 7 entered). Accordingly, in light of the protective order already entered in this case, the Court 8 should order Apple immediately produce a copy of the requested tool. B. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Tool. Displaylink Corp. v. Magic Control Tech. Corp., 2008 As An Alternative, The Court Should Permit Elan’s Expert and Counsel to Inspect the Tool On Demand Without Videotaping Although the tool is not source code, in an attempt to resolve this issue Elan at first agreed inspect the at a facility of Apple’s choosing and to thereafter meet and confer regarding formal testing and the production of any data produced from that testing tool (Rathinasamy Decl., Ex. H [4/12/2011 P. Rathinasamy e-mail to D. Walter]). Now, after two months, Elan has not even been able to secure that initial inspection for its expert or for all the Accused Products. Moreover, Apple now makes the blanket demand that any inspection by Elan’s expert be videotaped by Apple’s counsel. The unreasonable delay Apple has so far imposed, and its unreasonable demand to videotape Elan’s counsel and its expert, underscores that Apple should simply be ordered to immediately provide Elan’s counsel with a copy of the Tool as it is used for each Accused Product. Should the Court nevertheless restrict Elan’s access to the Tool to inspection at Apple’s counsel’s office, any such inspection may not be videotaped. First, Elan’s counsel would be present with Elan’s expert during at least the initial inspection and likely for future evaluations. The parties have agreed that expert’s work product and communications between experts and counsel are not discoverable and any such videotaping would violate this agreement. Second, even if the tool is considered “source code” (the only reason under the protective order to enforce limited inspections), the provisions of the Amended Stipulated Protective Order that Apple itself drafted and insisted upon bars Apple from videotaping. That Order states in relevant part that “[t]he Producing Party may visually monitor the activities of the ELAN’S MOT. TO COMPEL APPLE TO PRODUCE TESTING TOOL 8 Case No. 5:09-cv-01531 RS (PSG) 1 Receiving Party’s representatives during any Source Code review, but only to ensure that no 2 unauthorized electronic records of Source Code are being created or transmitted in any way” (Dkt. 3 No. 64 at 11-12) (emphasis added). Importantly, none of the Source Code inspections by either 4 side have involved any videotaping. 5 Certainly the intrusive nature of Apple’s request is extraordinary, but Apple has not and 6 cannot justify this request. Apple’s insistence on videotaping is not based on analogous case law 7 supporting Apple’s position. Rather, Apple makes this extraordinary request for the sole purpose 8 of making its cross-examination of Elan’s expert more convenient. As justification for its demand 9 Apple argues that “any testimony that [Elan’s expert] offers on these issues will no doubt be 10 informed by his testing” of the tool (Rathinasamy Decl., Ex. O [5/24/2011 D. Walter e- 11 mail to P. Rathinasamy]). While that may be true, any such opinions, and the factual bases for 12 them, will be provided in Elan’s expert’s report. See Fed. R. Civ. P. 26(a)(2). To the extent there 13 is any confusion or suspicion on Apple’s part as to the soundness of those opinions it has all of the 14 ways available to test those opinions are available in every other patent litigation context. See, 15 e.g., Melender-Diaz v. Mass., 129 S. Ct. 2527, 2536-38 (2009) (noting the utility of cross- 16 examination to weed out questionable scientific analysis). First, Apple can test any opinions 17 based on data obtained from the 18 deposition or at trial. Certainly Apple has capable counsel in this regard. For example its lead 19 counsel, Mr. Powers, and Mr. Bobrow have both recently been recognized as “Leading IP 20 Lawyers in California” (Rathinasamy Decl., Ex. Q [Press Release obtained from Weil.com]). 21 Presumably either one or both of these gentlemen can arrange to videotape any such deposition 22 and fully examine Elan’s expert on this topic. Furthermore, to the extent Elan’s expert were 23 somehow misusing or misrepresenting the 24 witnesses the engineers who created and use the tool, as well as its own expert familiar with the 25 tool. Any or all of these individuals could provide evidence to counter any suspect opinion. In 26 short, Apple fails to explain why such a drastic restriction on Elan’s ability to prepare its case for 27 trial is justified in this, a common patent litigation situation. through cross examination during a and its data, Apple has available to it as fact 28 ELAN’S MOT. 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