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Legacy Data Access, LLC v. Mediquant, Inc.

Legacy Data Access, LLC v. Mediquant, Inc.

United States District Court for the Western District of North Carolina, Charlotte Division

December 4, 2017, Decided; December 4, 2017, Filed

DOCKET NO. 3:15-cv-00584-FDW-DSC

Opinion

ORDER

THIS MATTER is before the Court upon the filing of several post-trial motions by Plaintiff and Defendant. Plaintiff has filed a Motion for Attorneys' Fees (Doc. No. 108), a Motion to Amend Judgment (Doc. No. 120), and a Motion for a Permanent Injunction (Doc. No. 123). Defendant has moved under Rule 59(a) for a new trial (Doc. No. 126), and in the alternative, moves under Rule 49(b) and 50(b) (Doc. No. 124). Defendant also seeks an amendment to the Judgment under Rule 59(e) (Doc. No. 126). All parties have responded to the pending motions, and they are now ripe for resolution. The Court addresses each motion but not necessarily in the order filed.

I. BACKGROUND

In the interests of judicial economy, the Court provides [*2]  a general overview of the case here but summarizes the specific background relevant to the issues raised by the parties' motions in the analysis. This litigation stems from William Jesse Rowland's resignation and departure from his position with Plaintiff and the acceptance and commencement of work for Defendant. After a six day trial, the jury found Defendant liable for (i) wrongfully interfering with the non-disclosure and non-competition provisions of the Employment, Non-Disclosure, Non-Solicitation, and Non- Competition Agreement (the "Agreement") between Rowland and Plaintiff; (2) misappropriation of trade secrets; (3) unfair or deceptive trade practices, and (4) punitive damages. The jury found that Defendant was not liable for wrongfully interfering with prospective contracts between Plaintiff and Ascension Health, Greenville Health System, El Camino, and Eskenazi. The jury awarded Plaintiff (1) $1 for wrongful interference with the non-disclosure and non-competition provisions of the Agreement; (2) $600,000 in damages for misappropriation of trade secret(s); and (3) $1 for unfair or deceptive trade practices. The jury also awarded Plaintiff $100,000 in punitive damages.

II. [*3]  ANALYSIS

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2017 U.S. Dist. LEXIS 198817 *; 2017 WL 6001637

LEGACY DATA ACCESS, LLC, Plaintiff, vs. MEDIQUANT, INC., Defendant.

Prior History: Legacy Data Access, LLC v. MediQuant, Inc., 2016 U.S. Dist. LEXIS 19109 (W.D.N.C., Feb. 17, 2016)

CORE TERMS

trade secret, unfair, misappropriation, matter of law, non-competition, damages, argues, attorney's fees, card, spoliation, deceptive, contends, deceptive trade practices, new trial, courts, tortious interference, actual damage, parties, provisions, prejudgment interest, punitive damages, geographic area, competitors, willful, interrogatories, non-disclosure, misappropriation of trade secrets, agency theory, denies, amend

Civil Procedure, Appeals, Standards of Review, Abuse of Discretion, Judgments, Relief From Judgments, Motions for New Trials, Trials, Judgment as Matter of Law, Harmless & Invited Errors, Harmless Error Rule, Evidence, Admissibility, Procedural Matters, Rulings on Evidence, Pleadings, Complaints, Requirements for Complaint, Trade Secrets Law, Misappropriation Actions, Elements of Misappropriation, Methods of Discovery, Depositions, Oral Depositions, Interrogatories, Purpose & Use of Interrogatories, Testimony, Lay Witnesses, Personal Knowledge, Remedies, Injunctions, Grounds for Injunctions, Preliminary & Temporary Injunctions, Jury Trials, Jury Instructions, Reversible Errors, Torts, Contracts, Intentional Interference, Elements, Jury Instructions, Requests for Instructions, Damages, Compensatory Damages, Monetary Damages, Judgment as Matter of Law, Directed Verdicts, Judgment Notwithstanding Verdict, Remedies, Burdens of Proof, Allocation, Labor & Employment Law, Conditions & Terms, Trade Secrets & Unfair Competition, Noncompetition & Nondisclosure Agreements, Federal & State Interrelationships, Choice of Law, Forum & Place, Business & Corporate Compliance, Protection of Secrecy, Trade Secrets Law, Protection of Secrecy, Civil Actions, Burdens of Proof, Protected Information, Damages, Definitions of Misappropriation, Injunctions, Business & Corporate Law, Agency Relationships, Agents Distinguished, Vicarious Liability, Agency Relationships, Authority to Act, Establishment, Duties & Liabilities, Authorized Acts of Agents, Liability of Principals, Corporations, Corporate Governance, Corporations, Civil Actions, Duties & Liabilities, Ratification, Express & Implied Ratification, Province of Court & Jury, Proof of Agency, Questions of Fact & Law, Authority to Act, Actual Authority, Express Authority, Scope, Sanctions, Misconduct & Unethical Behavior, Relevance, Preservation of Relevant Evidence, Spoliation, Eligibility for Sanctions, Parties Subject to Sanction, Knowledge & Notice, Verdicts, General Verdicts, Special Verdicts, Inconsistent Verdicts, Employment Relationships, Employment Contracts, Contract Interpretation, Inferences & Presumptions, Presumptions, Particular Presumptions, Governments, Legislation, Interpretation, Contracts Law, Contract Interpretation, Intent, Employee Duties & Obligations, Right to Compete, Covenants Not to Compete, Particular Presumptions, Regularity, Customer Solicitation, Altering & Amending Judgments, Business Torts, Unfair Business Practices, Standards of Review, Unfair Competition, Unfair Business Practices, Commercial Interference, Employment Relationships, Punitive Damages, Judgment Interest, Prejudgment Interest, Attorney Fees & Expenses, Basis of Recovery, Statutory Awards, Costs & Attorney Fees, Costs & Attorney Fees, Reasonable Fees, Basis of Recovery, Judicial Officers, Judges, Discretionary Powers, Irreparable Harm, Grounds for Injunctions