SAN FRANCISCO (LN) — U.S. Magistrate Judge Nathanael M. Cousins granted EchoSpan’s motion to vacate an amended judgment entered in favor of Medallia and ordered the entry of a second amended judgment reinstating the original jury verdict on May 14.
The ruling resolves post-trial procedural disputes that arose after a unanimous jury found Medallia willfully misappropriated one of EchoSpan’s trade secrets, identified as Trade Secret 6, under the Defend Trade Secrets Act and Georgia Trade Secrets Act.
The jury awarded EchoSpan $11.7 million in unjust enrichment and $14 million in exemplary damages.
Medallia had moved for judgment as a matter of law, arguing the damages evidence did not provide a reasonable basis for the jury’s award. The district court initially granted that motion, entering an amended judgment in Medallia’s favor on the damages claim.
EchoSpan appealed the grant of judgment as a matter of law to the Ninth Circuit.
The appellate court reversed, finding the jury had a reasonable basis for the unjust enrichment damages and remanding the case with instructions to reinstate the jury’s verdict.
Medallia then filed a motion for reconsideration of the court’s earlier order denying its request to treat the damages verdict as advisory. Medallia argued that unjust enrichment and exemplary damages are equitable issues that require independent findings of fact and conclusions of law under Federal Rule of Civil Procedure 52(a).
Cousins denied the motion, finding Medallia failed to meet its burden to show an intervening change in controlling law.
The magistrate judge rejected Medallia’s reliance on several cases, noting that three of the four authorities cited were not controlling law. The court pointed out that one was an unpublished Ninth Circuit decision and two were from other circuits.
The only controlling authority Medallia cited, Rearden LLC v. Walt Disney Pictures, did not squarely address the Defend Trade Secrets Act or Georgia Trade Secrets Act, Cousins wrote. The court found Rearden affirmed a district court’s order striking a jury demand on disgorgement under the Copyright Act, but did not establish a new rule for trade secret statutes.
EchoSpan had argued the Ninth Circuit’s mandate foreclosed the district court from reconsidering the Rule 52(a) order. Cousins disagreed, ruling the mandate only directed the court to reinstate the jury verdict and did not preclude consideration of other issues affecting the final judgment.
The court also declined to find that Medallia waived its argument by failing to file a cross-appeal, exercising its discretion to reach the issue of fairness.
Cousins noted the case has lasted nearly five years, involving a full jury trial, extensive post-trial motions, and a trip to the Ninth Circuit.
The court ordered a second amended judgment to follow.