Intus Care, Inc. v. RTZ Associates, Inc.
4:24-cv-01132
| N.D. Cal. | Sep 18, 2025Background
- IntusCare, Inc. sues RTZ Associates, Inc. in the N.D. Cal. over alleged information access issues related to PACECare, a EHI management system used by PACE facilities.
- RTZ licenses PACECare and prohibits sharing login credentials; its guidance suggests clients share exported reports rather than direct access.
- Intus developed a product to analyze data from EHRs and sought access to PACECare data for its analytics.
- From June 2021 to September 2022 Intus used automated scripts to extract data from PACECare; RTZ claims Intus lacked authorized access and never obtained consent.
- RTZ contends Intus used RTZ client credentials and that Intus never signed RTZ’s NDA; RTZ asserted negotiations for access terms were unsuccessful.
- Intus asserts RTZ blocked access since March 15, 2024, causing client terminations, while RTZ claims limited access attempts could be salvaged via reports; factual disputes remain.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RTZ engaged in information blocking under the Cures Act | Intus: RTZ blocked access through contract/credentials, triggering information blocking. | RTZ: Intus lacked NDA/de facto access; no information blocking if terms blocking access were negotiable. | Facial information blocking established; RTZ bears burden to show an exception. |
| Whether the manner or infeasibility exceptions apply to RTZ's conduct | Intus argues no applicable exception; RTZ failed to demonstrate feasible alternative. | RTZ asserts the manner/infeasibility exceptions apply due to inability to reach terms or fulfill request as requested. | Disputed facts prevent summary judgment on both exceptions; denial of motion on this point. |
Key Cases Cited
- Real Time Med. Sys., Inc. v. PointClickCare Techs., Inc., 131 F.4th 205 (4th Cir. 2025) (definitional scope of information blocking and regulatory exceptions under Cures Act)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard requiring movant to show absence of genuine issue)
- Nissan Fire & Marine Ins. Co. v. Fritz Cos., 210 F.3d 1099 (9th Cir. 2000) (burden-shifting framework for summary judgment)
- C.A.R. Transp. Brokerage Co. v. Darden Rests., Inc., 213 F.3d 474 (9th Cir. 2000) (burden allocation on summary judgment in the Ninth Circuit)
- Keenan v. Allan, 91 F.3d 1275 (9th Cir. 1996) (admissibility and burden considerations in summary judgment context)