Summary
This Memorandum Opinion and Order from the U.S. District Court for the Eastern District of Texas grants Plaintiff PLS IV, LLC’s Motion to Compel discovery from Defendant GDC Technology Limited. The Court determined that customer-specific information regarding sales of accused digital cinema products is relevant to claims of indirect infringement and damages, and proportional to the needs of the case. The order compels the defendant to produce the requested information within ten days.
Topics
Practice areas
Questions Presented
- Whether customer-specific information concerning GDC's accused products was relevant to PLS's indirect-infringement and damages theories.
- Whether production of the customer-specific information was proportional to the needs of the case.
Holdings
- Customer-specific information concerning the accused products was relevant and within the scope of permissible discovery because it could reasonably lead PLS to identify instances of direct infringement necessary to prove indirect infringement and could bear on damages.
- Production of the customer-specific information was proportional to the needs of the case.
Key quotations
“Here, GDC’s customer information could reasonably lead to PLS identifying instances of direct infringement that are necessary to prove indirect infringement.” (Analysis)
“Accordingly, the Court COMPELS GDC to produce customer-specific information responsive to PLS’s Interrogatories Nos. 2-4 from December 2011 to June 2023” (Conclusion)
Factual background
PLS alleged that GDC directly, indirectly, or contributorily infringed four patents relating to controlling the use of digital content through software modules and computer systems. PLS's interrogatories sought customer identities and locations, indemnification information, sales information, and information concerning GDC's assistance to customers using accused products. GDC produced invoices but refused to provide the requested customer-specific information, asserting that it was irrelevant and disproportionate.
Procedural history
PLS filed a patent-infringement complaint against GDC on June 21, 2024. PLS served its First Set of Interrogatories on February 10, 2025, and GDC responded on March 21, 2025, producing invoices but refusing to provide customer names and other customer-specific information. The district court granted PLS's motion to compel and ordered production within ten days.
Remand instructions
No remand. GDC was compelled to produce customer-specific information responsive to PLS's Interrogatories Nos. 2-4 for December 2011 through June 2023 within ten days of the order.