Micron Tech., Inc. v. Rambus, Inc., No. 00-792-SLR (D. Del. Jan. 2, 2013)
Following remand from the Federal Circuit, the District Court considered the question of “whether Rambus acted in bad faith when it engaged in spoliation and the nature and extent of any prejudice suffered by Micron as a result . . . .” and found that “Rambus’ spoliation was done in bad faith, that the spoliation prejudiced Micron, and that the appropriate sanction [was] to declare the patents-in-suit unenforceable against Micron.”
This patent infringement case has an interesting history. Briefly stated, the District Court in the District of Delaware held, in 2009, “that Rambus had engaged in unlawful spoliation of discoverable documents and that the patents-in-suit where unenforceable against Micron as a result.” (See summary, here.) The finding of spoliation was affirmed on appeal, but the case was remanded for further consideration of the court’s “bad faith and prejudice determinations . . . as well as the appropriate sanction . . . .” (See summary, here.) On remand, the District Court again found that Rambus’ spoliation was in bad faith, that Micron was prejudiced as a result, and that the appropriate sanction was to once again declare the patents-in-suit unenforceable against Micron.
Regarding the question of bad faith, the court noted that “the ‘fundamental element of bad faith spoliation is advantage-seeking behavior by the party with superior access to information necessary for the proper administration of justice’” and identified several “categories of facts” which supported a finding of bad faith in the present case:
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Source: ediscoverylaw.com
Following remand from the Federal Circuit, the District Court considered the question of “whether Rambus acted in bad faith when it engaged in spoliation and the nature and extent of any prejudice suffered by Micron as a result . . . .” and found that “Rambus’ spoliation was done in bad faith, that the spoliation prejudiced Micron, and that the appropriate sanction [was] to declare the patents-in-suit unenforceable against Micron.”
This patent infringement case has an interesting history. Briefly stated, the District Court in the District of Delaware held, in 2009, “that Rambus had engaged in unlawful spoliation of discoverable documents and that the patents-in-suit where unenforceable against Micron as a result.” (See summary, here.) The finding of spoliation was affirmed on appeal, but the case was remanded for further consideration of the court’s “bad faith and prejudice determinations . . . as well as the appropriate sanction . . . .” (See summary, here.) On remand, the District Court again found that Rambus’ spoliation was in bad faith, that Micron was prejudiced as a result, and that the appropriate sanction was to once again declare the patents-in-suit unenforceable against Micron.
Regarding the question of bad faith, the court noted that “the ‘fundamental element of bad faith spoliation is advantage-seeking behavior by the party with superior access to information necessary for the proper administration of justice’” and identified several “categories of facts” which supported a finding of bad faith in the present case:
To Continue Reading: Click Here
-----------------------------------------------------
Source: ediscoverylaw.com
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