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    Alcoa Inc. v. Universal Alloy Corporation - 20

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    mike_songer_1
    Universal Alloy Corporation filed a motion requesting that Alcoa Inc. be required to identify the trade secrets at issue in their case before the start of discovery. Universal Alloy argues that identifying the trade secrets early will allow it to understand what Alcoa claims it did and prepare its defense accordingly. It will also help distinguish relevant discovery from attempts to obtain competitive information. Most importantly, early identification would prevent Alcoa from molding its trade secret claims based on information produced during discovery. Universal Alloy asks the court to grant its motion and order Alcoa to identify its alleged trade secrets within two weeks of a protective order being entered.

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    Alcoa Inc. v. Universal Alloy Corporation - 20

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    mike_songer_1
    301 views5 pages
    Universal Alloy Corporation filed a motion requesting that Alcoa Inc. be required to identify the trade secrets at issue in their case before the start of discovery. Universal Alloy argues that identifying the trade secrets early will allow it to understand what Alcoa claims it did and prepare its defense accordingly. It will also help distinguish relevant discovery from attempts to obtain competitive information. Most importantly, early identification would prevent Alcoa from molding its trade secret claims based on information produced during discovery. Universal Alloy asks the court to grant its motion and order Alcoa to identify its alleged trade secrets within two weeks of a protective order being entered.

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    Alcoa Inc. v. Universal Alloy Corporation_20

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    Universal Alloy Corporation filed a motion requesting that Alcoa Inc. be required to identify the trade secrets at issue in their case before the start of discovery. Universal Alloy argues that identifying the trade secrets early will allow it to understand what Alcoa claims it did and prepare its defense accordingly. It will also help distinguish relevant discovery from attempts to obtain competitive information. Most importantly, early identification would prevent Alcoa from molding its trade secret claims based on information produced during discovery. Universal Alloy asks the court to grant its motion and order Alcoa to identify its alleged trade secrets within two weeks of a protective order being entered.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    301 views5 pages

    Alcoa Inc. v. Universal Alloy Corporation - 20

    Uploaded by

    mike_songer_1
    Universal Alloy Corporation filed a motion requesting that Alcoa Inc. be required to identify the trade secrets at issue in their case before the start of discovery. Universal Alloy argues that identifying the trade secrets early will allow it to understand what Alcoa claims it did and prepare its defense accordingly. It will also help distinguish relevant discovery from attempts to obtain competitive information. Most importantly, early identification would prevent Alcoa from molding its trade secret claims based on information produced during discovery. Universal Alloy asks the court to grant its motion and order Alcoa to identify its alleged trade secrets within two weeks of a protective order being entered.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 5

    Case 1:15-cv-01466-ELR Document 20 Filed 05/29/15 Page 1 of 5

    IN THE UNITED STATES DISTRICT COURT


    FOR THE NORTHERN DISTRICT OF GEORGIA
    ATLANTA DIVISION
    ALCOA INC.,
    Plaintiff,
    v.
    UNIVERSAL ALLOY,
    CORPORATION
    Defendant.

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    Civil Action No.:


    1:15-cv-01466-ELR

    DEFENDANT UNIVERSAL ALLOY CORPORATIONS


    MOTION FOR ORDER REQUIRING
    PRE-DISCOVERY IDENTIFICATION OF TRADE SECRETS
    Defendant Universal Alloy Corporation (UAC) hereby moves the Court to
    order Alcoa Inc. (Alcoa) to identify pre-discovery the trade secrets Alcoa alleges
    are at issue in this case. UAC requests that the Court order Alcoa to identify its
    alleged trade secrets with specificity within two weeks of entry of an appropriate
    protective order and before discovery against UAC commences.
    In support of this Motion, UAC contemporaneously filed a Memorandum of
    Law describing the reasons for granting this Motion in greater detail. The
    Memorandum of Law accompanying this Motion demonstrates the Court should
    require Alcoa to make this basic, foundational disclosure at the outset so that (1)
    UAC can understand precisely what Alcoa claims it has done and can prepare to

    Case 1:15-cv-01466-ELR Document 20 Filed 05/29/15 Page 2 of 5

    defend itself accordingly; (2) the Court and UAC can distinguish relevant
    discovery from attempts to fish for competitive information; and (3) most
    importantly, Alcoa cannot mold its trade-secret claims to mirror whatever
    information UAC produces during discovery.
    For the reasons stated herein and in the accompanying Memorandum of
    Law, UAC respectfully asks the Court to grant its Motion, order Alcoa to identify
    its alleged trade secrets as described above, and for all other just and proper relief.
    Respectfully submitted, this 29th day of May, 2015.
    By:

    /s/ Michael J. Sullivan


    Michael J. Sullivan
    Georgia Bar No. 142203
    Julie E. Adkins
    Georgia Bar No. 871742
    WOMBLE CARLYLE SANDRIDGE &
    RICE LLP
    271 17th Street NW #2400
    Atlanta, GA 30363
    Telephone: (404) 872-7000
    Facsimile: (404) 888-7490
    [email protected]
    [email protected]
    AND
    David K. Herzog
    Katrina M. Gossett
    Matthew E. Burkhart
    FAEGRE BAKER DANIELS LLP
    300 N. Meridian Street
    -2-

    Case 1:15-cv-01466-ELR Document 20 Filed 05/29/15 Page 3 of 5

    Suite 2700
    Indianapolis, Indiana 46204
    Telephone: (317) 237-0300
    Facsimile: (317) 237-1000
    [email protected]
    [email protected]
    [email protected]
    (pro hac vice applications pending)
    AND
    Randall E. Kahnke
    Kerry L. Bundy
    Tyler A. Young
    FAEGRE BAKER DANIELS LLP
    2200 Wells Fargo Center
    90 South Seventh Street
    Minneapolis, Minnesota 55402
    Telephone: (612) 766-7000
    Facsimile: (612) 766-1600
    [email protected]
    [email protected]
    [email protected]
    (pro hac vice applications pending)
    Attorneys for Universal Alloy Corporation

    -3-

    Case 1:15-cv-01466-ELR Document 20 Filed 05/29/15 Page 4 of 5

    CERTIFICATE OF SERVICE
    The undersigned hereby certifies that a true and correct copy of the
    foregoing DEFENDANT UNIVERSAL ALLOY CORPORATIONS
    MOTION FOR ORDER REQUIRING PRE-DISCOVERY
    IDENTIFICATION OF TRADE SECRETS has been served upon the following
    counsel of record via CM/ECF:
    J. Allen Maines
    Mellori E. Lumpkin
    Holland & Knight LLP
    One Atlantic Center, Suite 2000
    1201 West Peachtree Street
    Atlanta, Georgia 30309

    The undersigned further certifies that a true and correct copy of the foregoing also
    has been served by placing same in the United States postal service with proper
    postage affixed thereto and addressed to the following:
    Thomas E. Birsic
    Melissa J. Tea
    James P. Angelo (pro hac vice admissions pending)
    K&L GATES LLP
    K&L Gates Center
    210 Sixth Avenue
    Pittsburgh, Pennsylvania 15222
    This 29th day of May, 2015.
    -4-

    Case 1:15-cv-01466-ELR Document 20 Filed 05/29/15 Page 5 of 5

    /s/ Michael J. Sullivan


    Michael J. Sullivan
    Georgia Bar No. 142203

    -5-

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