Oracle America, Inc. v. Procore Technologies, Inc.

Summary

The United States District Court for the Northern District of California denied Procore Technologies, Inc.’s motion to quash subpoenas served on seven nonparty former Oracle customers. The court held that Procore lacked standing to challenge the subpoenas based on alleged burdens to its customers, business relationships, or proprietary information, and found that the requested discovery was relevant to Oracle’s trade-secret misappropriation claims. The court directed the parties to confer regarding protection under the existing protective order.

Holdings

1. Procore lacked standing to challenge the subpoenas because it asserted only the potential burden on its customers, disruption to its business relationships, and an interest in confidential or proprietary information, none of which established a privilege or personal right sufficient to confer standing on this record.
2. The court did not require Oracle to wait for or repeat party discovery before proceeding with the nonparty subpoenas.
3. The subpoenas sought relevant, discoverable information concerning Oracle's trade-secret-misappropriation claim, and the court permitted the discovery absent objections based on burden or overbreadth.

Questions Presented

1. Whether Procore had standing to move to quash subpoenas issued to nonparty former customers.
2. Whether the subpoenas sought relevant and discoverable information under Federal Rules of Civil Procedure 26 and 45.
3. Whether party discovery had to precede the nonparty discovery.

Disposition

other