Trilogy Federal, LLC v. Civitasdx LLC
Civil Action No. 2024-2713
| D.D.C. | May 5, 2025Background
- Trilogy Federal, a contractor with specialized financial management expertise, sued multiple defendants (CivitasDX, CMS, Halfaker, SAIC, Client First, and Thomas) for misappropriation of trade secrets and interference with business related to a VA financial systems contract.
- At the same time, Trilogy sued GDIT in a separate but factually similar case for the same legal claims; different counsel handled the cases to avoid conflicts.
- After initial motions and amendments, all Trilogy’s claims (except those against GDIT) were consolidated in this case, while the GDIT case is stayed pending arbitration.
- Defendants moved to further consolidate the GDIT case with this one and to stay proceedings here pending the outcome of the arbitration between Trilogy and GDIT.
- Trilogy opposed this motion; briefing was completed, and the court now addresses whether to consolidate or stay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to consolidate this case with the GDIT case | No strong objection, but initial separation for conflict reasons | Consolidation needed due to common factual and legal issues, aids efficiency | Denied; cases in different procedural postures, no efficiency gain |
| Whether to stay this case pending GDIT arbitration | Stay would prejudice Trilogy through indefinite delay; not all claims would be resolved | Stay warranted as arbitration outcome could be preclusive; preparations here inefficient | Denied; potential efficiency speculative, delay harms Trilogy |
Key Cases Cited
- Landis v. N. Am. Co., 299 U.S. 248 (courts may grant a stay but must weigh hardship and fairness, and not order indefinite stays without pressing need)
- Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (stays in favor of arbitration are discretionary and piecemeal adjudication can be required by federal law)
- Ryan v. Gonzales, 568 U.S. 57 (decision to grant a stay is within the district court's discretion)
- Moten v. Bricklayers, Masons & Plasterers Int’l Union of Am., 543 F.2d 224 (consolidation decisions left to the sound discretion of the district court)