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IQVIA Inc. v. Veeva Systems, Inc.

United States District Court, D. New Jersey

September 13, 2018

IQVIA, INC. and IMS SOFTWARE SERVICES, LTD, Plaintiffs/ Counterclaim Defendants,
v.
VEEVA SYSTEMS, INC., Defendant/ Counterclaim Plaintiff.

          ORDER & OPINION OF THE SPECIAL MASTER

          DENNIS M. CAVANAUGH U.S. D. J.

         This matter comes before the Special Master on Defendant-Counterclaim Plaintiff Veeva Systems, Inc.'s ("Veeva") motion to compel Plaintiffs-Counterclaim Defendants IQVIA, Inc. and IMS Software Services, LTD, (collectively "IQVIA") to provide responses to Interrogatory Nos. 33-35. After considering the submissions of the parties, based upon the following, it is the opinion of the Special Master that Veeva's motion is DENIED.

         DISCUSSION

         I. Discovery Standard

         Interrogatories are a discovery device designed "to obtain simple facts ..." and "can be a simple mode of obtaining the names and addresses of persons having knowledge of pertinent facts, or of securing information about the existence of documentary evidence[.]" Erie Ins. Property & Cas. Co. v. Johnson, 272 F.R.D. 177, 183 (S.D. W.Va. 2010)(quoting Wright, Miller, & Marcus, Federal Practice & Procedure: Civil 3d § 2163). "A responding party generally is not required to conduct extensive research to answer an interrogatory, but ... must make a reasonable effort to respond." Legends Mgmt. Co., LLC v. Affiliated Ins. Co., No. 2:16- CV-01608-SDW-SCM, 2017 WL 4618817, at *3 (D.N.J. Oct. 13, 2017). The responding party must respond "to the fullest extent possible, stating any objections with specificity." Reyes v. City of Paterson, No. 2:16-CV-2627, 2017 WL 1536425, at *2 (D.N.J. Apr. 28, 2017) (citing Fed.R.Civ.P. 33(b)(3) and (4)); see also Lamon v. Adams, 2014 WL 309424 at *3 (E.D. Cal. 2014).

         II. Interrogatory Nos. 33, 34 & 35

         Interrogatory No. 33

         Identify with precision and specificity any facts (including without limitation any fact contained in Veeva's October 20, 2017 or Veeva's April 27, 2018 responses to IQVIA's Interrogatory No. 1) that IQVIA knew of when it filed its Complaint or learned of since the filing of its Complaint, that IQVIA contends is evidence of an act of trade secret misappropriation; and if none so state.

         Response

         IQVIA's Complaint makes clear the basis for the filing of this Action, and the factual statements contained in the Complaint relating to Veeva's theft of trade secrets are incorporated in this response. IQVIA further incorporates its responses to Interrogatory Nos. 16, 19, 20, 21, 22, 25, 26, and 27. Further, Veeva disclosed, among other things, information to IQVIA regarding Veeva's data management practices, the design of Veeva's CRM and MDM applications, the structure and operation of Veeva technical support and development processes, Veeva's staffing practices, and the integration of employees within facilities across functions and roles during the course of the various discussions among the representatives of Veeva and IQVIA from late 2013 through 2016, some of which were confirmed by the Ernst and Young Assessment.

         Interrogatory No. 34

         For each fact IQVIA knew of at the time it filed its Complaint, or has learned of since the filing of its Complaint (including without limitation any fact contained in Veeva's October 20, 2017 or Veeva's April 27, 2018 Responses to IQVIA's Interrogatory No. 1), which IQVIA contends is evidence of an act of trade secret misappropriation, identify with precision and specificity the precise information IQVIA contends constitutes the IQVIA trade secret associated with each such alleged act of trade secret misappropriation.

         IQVIA

         IQVIA contends that its Market Research Offerings and any derivation from those Market Research Offerings are IQVIA trade secrets. Thus, any access and use by Veeva of those Market Research Offerings, or any access and use of derivations from those Market Research Offerings by Veeva, for any purpose not permitted in a Third Party Access Agreement or any access and use of those Market Research Offerings by Veeva without a Third Party Access Agreement, constitutes a trade secret misappropriation by ...


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