Slip Opinion
N.D. Cal.Jun 30, 2025Background
- Celonis, a process mining company, filed suit against SAP, alleging antitrust violations and state law claims related to SAP’s conduct in the U.S. market.
- The core dispute centers around SAP's alleged restriction of customer data extraction methods, potentially forcing customers to use SAP's Signavio product over Celonis’s offerings.
- Some related conduct is being litigated in Germany, but this U.S. case focuses on American antitrust law and effects on U.S. consumers and competitors.
- Celonis also alleges SAP engaged in unlawful tying, predatory pricing, bundling, monopolization, false advertising, and tortious interference.
- SAP moved to dismiss all claims; the court granted the motion in part and denied in part, allowing only the interference with contractual relations claim to proceed at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Comity & Forum Non Conveniens | U.S. antitrust law and effects on U.S. parties are at issue | German litigation already addresses the conduct | U.S. court is proper forum |
| Tying | SAP ties Signavio to ERP data access, harming Celonis | Celonis’s extractor not covered by relevant SAP policies | Dismissed – insufficient tying allegation |
| Bundling/Predatory Pricing | SAP bundles/sells below cost to exclude rivals | Lack of detail on pricing and costs, allegations speculative | Dismissed – insufficient below-cost pricing detail |
| Monopolization/Attempted Monopolization | SAP’s restrictions are anticompetitive conduct | No obligation to allow competitors database access as preferred | Dismissed – insufficient anticompetitive conduct |
| False Advertising | SAP made false/misleading statements to customers | No specifics or public dissemination alleged | Dismissed – insufficient specificity/dissemination |
| UCL | SAP's conduct violates California UCL | No alleged conduct or harm in California | Dismissed – no California nexus |
| Tortious Interference w/ Contractual Relations | SAP’s conduct disrupted existing Celonis contracts | Disruption, if any, not actionable | Not dismissed – claim survives |
| Tortious Interference w/ Prospective Econ. Advantage | SAP’s conduct harmed prospective business damage | No independent wrongful act alleged | Dismissed |
Key Cases Cited
- In re Korean Ramen Antitrust Litigation, 281 F. Supp. 3d 892 (N.D. Cal. 2017) (forum non conveniens analysis in U.S. antitrust context)
- Reveal Chat Holdco, LLC v. Facebook, Inc., 471 F. Supp. 3d 981 (N.D. Cal. 2020) (no duty for platform to allow competitor-accessed data)
- Novell, Inc. v. Microsoft Corp., 731 F.3d 1064 (10th Cir. 2013) (refusal-to-deal claims standard)
- Ariix, LLC v. NutriSearch Corp., 985 F.3d 1107 (9th Cir. 2021) (false advertising dissemination requirement)