Law School Case Brief
Self Directed Placement Corp. v. Control Data Corp. - 908 F.2d 462 (9th Cir. 1990)
Fed. R. Civ. P. 8(a)(2) requires that a pleading contain a short and plain statement of the claim showing that the pleader is entitled to relief. The rule further states that all pleadings shall be so construed as to do substantial justice. Fed. R. Civ. P. 8(f). Courts recognize that the main purpose of the complaint is to provide notice to the defendant of what plaintiff's claim is and the grounds upon which the claim rests. Notice to the defendant of the mere existence of a grievance is not enough, and while it is not necessary that plaintiff state sufficient facts to constitute a cause of action, plaintiff must at least set forth enough details so as to provide defendant and the court with a fair idea of the basis of the complaint and the legal grounds claimed for recovery.
Self Directed was engaged in the business of providing training courses to unemployed and under-employed individuals. Control Data was engaged in the business of providing computer related vocational training courses. In 1981, Alvis Swinney, Control Data's chief "trouble shooter" initiated negotiations with Self Directed for the purpose of licensing the Self Directed program to assist Control Data in solving its placement difficulties. Following a series of negotiations, the parties agreed that Self Directed would first conduct a "pilot" program for Control Data. Lois Trager, an employee of Self Directed who had signed a Secrecy Agreement, was one of the instructors during this pilot program. Alvis Swinney attended part of the Anaheim program and during the program Swinney offered Trager a substantially higher paying job with Control Data. At Control Data Trager was assigned the task of putting a program together "using SDP, using what she had learned in Anaheim on the program". Soon thereafter, Control Data ceased communications with Self Directed. Plaintiffs sued defendants for, inter alia, violation of the Copyright Act, 17 U.S.C.S. § 102, et seq., misappropriation of trade secrets and unfair competition. The district court granted defendants' motion for summary judgment while a motion to compel additional discovery was still pending.
Was the district court correct in granting summary judgment during the pendency of a motion to compel additional discovery in an action for copyright violations, misappropriation of trade secrets, and unfair competition?
On appeal, the court affirmed in part, holding that summary judgment on liability would not have been altered by additional discovery because the requested discovery was related to damages only. Thus, there was no abuse of discretion in granting summary judgment with the motion to compel pending. Further, the district court correctly held that plaintiffs' claims were not secret and were a matter of common public knowledge. Thus, there could be no misappropriation of trade secrets. However, because plaintiff had sufficiently pleaded unfair competition and the district court had not addressed that claim, the case was remanded for determination of that claim.
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