Wright's Well Control Services, LLC v. Oceaneering International, Inc. et al, No. 2:2015cv01720 - Document 78 (E.D. La. 2016)

Court Description: ORDER AND REASONS denying 55 Motion to Bifurcate. Signed by Judge Sarah S. Vance on 2/25/16. (jjs)

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Wright's Well Control Services, LLC v. Oceaneering International, Inc. et al Doc. 78 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA WRIGHT'S WELL CONTROL SERVICES, LLC CIVIL ACTION VERSUS NO: 15-1720 OCEANEERING INTERNATIONAL, INC. AND CHRISTOPHER MANCINI SECTION: R ORD ER AN D REASON S Before the Court is plaintiff Wright's Well Control Services's ("WWCS") m otion for separate trials on its patent infringem ent claim and its state law claim s against defendants Oceaneering International, Inc. and Christopher Mancini. For the following reasons, the m otion is denied. I. BACKGROU N D This case centers on a technological system for rem oving hydrates from subsea, deepwater pipelines.1 WWCS alleges that it developed a hydrate remediation system that offered many advantages over competing systems and provided a faster, safer, and m ore cost-effective way to clear hydrates in deepwater environm ents. WWCS then joined with defendant Oceaneering to 1 Unless otherwise noted, the Court draws these facts from a prior order in this case. See R. Doc. 56. Dockets.Justia.com com plete a num ber of joint hydrate rem ediation projects using WWCS's technology. In furtherance of this arrangem ent, the parties executed a nondisclosure agreem ent ("NDA"), which restricted each party's use of confidential and proprietary inform ation that it received under the NDA. WWCS alleges that Oceaneering and one of its em ployees, Mancini, ignored these restrictions and used WWCS's proprietary inform ation to build their own hydrate rem ediation system . WWCS further alleges that Oceaneering used this system to com pete against WWCS for hydrate rem ediation projects. According to WWCS, after the parties executed the NDA, David Wright and J effrey Dufrene filed a patent application claim ing, am ong other things, the subsea separator em ployed in WWCS' hydrate rem ediation system . The application was granted, and Wright and Dufrene assigned all rights and interests in U.S. Patent Num ber 8,413,725 (the "'725 Patent") to WWCS. WWCS charged Oceaneering with direct and indirect infringem ent of the '725 patent. WWCS filed this suit on May 21, 20 15 pleading patent infringem ent, breach of contract, and num erous tort claim s against Oceaneering and Mancini.2 WWCS also alleged that both defendants m isappropriate its trade 2 R. Doc. 1. 2 secrets in violation of both the Texas Uniform Trade Secrets Act (TUTSA) and the Louisiana Uniform Trade Secrets Act (LUTSA). Defendants m oved to dism iss every non-patent claim under Federal Rule of Civil Procedure 12(b)(6), arguing that each claim was tim e-barred and raising other challenges to the sufficiency of WWCS's pleadings. On Novem ber 11, 20 16, the Court granted in part and denied in part defendants' m otion, dism issing WWCS's TUTSA claim s and certain breach of contract claim s with prejudice and dism issing WWCS's fraudulent inducement claims without prejudice and with leave to am end.3 On Decem ber 8, 20 15, WWCS filed its second am ended com plaint re-alleging m any of its prior causes of action. 4 WWCS now m oves to bifurcate this case into separate trials under Federal Rule of Civil Procedure 42(b).5 Specifically, WWCS contends that the Court should separate issues relating to its patent infringem ent claim from issues relating to its trade secret m isappropriation, breach of contract, and other claim s under state law. According to WWCS, this arrangem ent will stream line this lawsuit, reduce the risk of juror confusion, and perm it faster resolution of WWC's state law causes of action. Defendants oppose the m otion 3 R. Doc. 56. 4 R. Doc. 69. 5 R. Doc. 55. 3 on a num ber of grounds, including that WWCS's patent and state law claim s are factually intertwined and that bifurcation would prejudice defendants by delaying final resolution of this case and increasing defendants' legal expenses.6 II. D ISCU SSION Under Federal Rule of Civil Procedure 42(b), a district court m ay order a separate trial of any claim "in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and econom y . . . ." Fed R. Civ. P. 42(b). Separate trials, however, are the exception, not the rule. See McDaniel v. Anheuser-Busch, Inc., 987 F.2d 298, 30 4 (5th Cir. 1993) ("Separation of issues, however, is not the usual course that should be followed."); Laitram Corp. v. Hew lett– Packard Co., 791 F.Supp. 113, 114-15 (E.D.La.1992) (noting that "in patent cases, as in others, separate trials should be the exception" and that "courts should not order separate trials unless such a disposition is clearly necessary."). Moreover, the Fifth Circuit has cautioned district courts that the "issue to be tried [separately] m ust be so distinct and separable from the others that a trial of it alone m ay be had without injustice." 6 R. Doc. 57. 4 Sw offord v. B & W , Inc., 336 F.2d 40 6, 415 (5th Cir. 1964) (citing Gasoline Prods. Co. v. Cham plin Ref. Co., 283 U.S. 494, 499-50 0 (1931)). WWCS argues that bifurcation is necessary to stream line this case and avoid the risk of confusing jurors through the sim ultaneous presentation of different facts and claim s. The Court finds this argum ent unpersuasive. In every lawsuit involving m ultiple claim s, jurors are required to weigh the evidence for each claim individually, and that obligation will present no undue burden on the jury in this case. See Lott v. Eastm an Kodak Co., No. 3:97-CV-2560 -P, 1999 WL 242688, at *4 (N.D. Tex. Apr. 16, 1999) (rejecting juror confusion claim ). Moreover, the Court can address any potential risk of prejudice or juror confusion by carefully instructing the jury on the applicable law. See Guedry v. Marino, 164 F.R.D. 181, 186 (E.D. La. 1995) (noting that the risk of jurors becom ing confused by the "sheer num ber of claim s presented . . . . can be addressed by instructions"). Nor are the specific circum stances cited by WWCS--its inability to post a bond in connection with a prior m otion for prelim inary injunctive relief--so unusual as to warrant bifurcation. Rather, the Court finds that bifurcation would not further the interests of judicial efficiency, convenience, or fairness. While bifurcation m ight facilitate quicker resolution of WWCS's state law causes of action, it would delay resolution of WWCS's patent infringem ent 5 claim , thereby prolonging the litigation between the parties. The Court finds that defendants would be prejudiced by the delay that would result if the Court ordered separate trials with separate discovery schedules. Laitram Corp., 791 F. Supp. at 116 (noting that unreasonable delay in disposition of the entire case would prejudice the party opposing bifurcation). These unnecessary expenses and delays outweigh any prejudice that would result from any potential confusion of trying all issues at once. After balancing the parties' com peting claim s of prejudice, considering the convenience to the Court and litigants, and assessing the interests of judicial econom y, the Court finds that these considerations weigh against WWCS's m otion to bifurcate. III. CON CLU SION For the foregoing reasons, plaintiff's m otion to bifurcate is DENIED. 25th New Orleans, Louisiana, this _ _ _ day of February, 20 16. _________________________________ SARAH S. VANCE UNITED STATES DISTRICT J UDGE 6

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