Cangrade, Inc. v. Synopsys, Inc.

Summary

The United States District Court for the Northern District of California addresses discovery disputes concerning requests for admission and production in Cangrade, Inc. v. Synopsys, Inc. The Court issues tentative rulings regarding settlement materials involving third-party Paylocity, investor communications, and requests concerning the existence of documents, and orders the parties to meet and confer or submit further joint statements.

Holdings

1. The fact of whether Cangrade received payment from Paylocity in settling the Massachusetts Action was relevant and proportional to the needs of the case. The court tentatively granted Synopsys's request for an admission or denial and alternatively tentatively ordered production of the final settlement agreement.
2. Settlement-related negotiation documents were at most tangentially relevant and, once the settlement agreement was produced, were not proportional to the needs of the case. The court tentatively denied the request for those documents.
3. The mediation privilege did not protect settlement-related documents created in the months after mediation or the settlement agreement itself.
4. Information need not be admissible in evidence to be discoverable.
5. Counsel must conduct a reasonable, diligent search under Rule 26(g), and the production of only one document across the subjects in RFP 4 raised a legitimate question about search sufficiency. Cangrade's counsel was ordered to search the two identified employees' emails and texts using terms sufficient to capture relevant communications after the scope of the request was resolved.
6. The RFAs seeking the existence or nonexistence of documents in reaction to the limited production under RFP 4 were improper because they were not directed to facts to be determined at trial and fell outside the parameters of Rule 36.

Questions Presented

1. Whether the fact of any payment received by Cangrade under its settlement with Paylocity and the settlement agreement were relevant and proportional to the needs of the case.
2. Whether settlement-related negotiation documents were protected by confidentiality, privilege, the mediation privilege, or Federal Rule of Evidence 408, or were otherwise disproportionate to the needs of the case.
3. Whether Cangrade was required to conduct a more thorough search for investor communications under Federal Rule of Civil Procedure 26(g).
4. Whether requests for admission concerning the existence or nonexistence of documents were proper under Federal Rule of Civil Procedure 36.
5. Whether evidence must be admissible to be discoverable under Federal Rule of Civil Procedure 26(b)(1).

Disposition

other