Medtronic Puerto Rico Operations Co v. Animas Corporation
2:12-cv-04471
C.D. Cal.Jun 25, 2013Background
- Plaintiffs Medtronic Minimed Inc., Medtronic Puerto Rico Operations Co., and Minimed Distribution Corp. sued Animas Corporation for infringement of nine patents related to insulin infusion pumps.
- Defendant moved to bifurcate liability and damages under Fed. R. Civ. P. 42(b) and to stay damages discovery until liability is resolved.
- The parties were mid-discovery with a final pretrial conference about one year away when the motion was decided.
- The Court recognized the broad discretion district courts have to bifurcate issues but noted bifurcation is an exception, not the rule, in the Ninth Circuit.
- The Court found it premature to bifurcate or to stay damages discovery given the unresolved scope of triable claims and ongoing discovery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to bifurcate liability and damages for trial | Opposed; bifurcation premature given discovery and unresolved issues | Bifurcation will promote efficiency and avoid unnecessary damages proceedings if liability is resolved against Defendant | Denied — premature at this stage; bifurcation is exceptional and issues remain unresolved |
| Whether to stay damages discovery pending liability determination | Opposed; discovery should continue to define triable issues | A stay would conserve resources until liability is decided | Denied — stay would be premature given ongoing discovery and upcoming pretrial schedule |
Key Cases Cited
- Zivkovic v. S. Cal. Edison Co., 302 F.3d 1080 (9th Cir. 2002) (district courts have broad discretion to bifurcate under Rule 42(b))
- Hangarter v. Provident Life & Accident Ins. Co., 373 F.3d 998 (9th Cir. 2004) (bifurcation is the exception rather than the rule)
- Clark v. I.R.S., 772 F. Supp. 2d 1265 (D. Haw. 2009) (discussing rarity of bifurcation in Ninth Circuit practice)
- Pinal Creek Group v. Newmont Mining Corp., 218 F.R.D. 652 (D. Ariz. 2003) (factors for bifurcation include convenience, prejudice, and efficiency)
- Stoddard v. Ling-Temco-Vought, Inc., 513 F. Supp. 314 (C.D. Cal. 1980) (court may bifurcate to avoid prejudice and promote convenience)
- Renfrow v. Redwood Fire & Cas. Ins. Co., 288 F.R.D. 514 (D. Nev. 2013) (bifurcation appropriate when resolution of an issue could dispose of the entire case)