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Data General Corp. v. Grumman Systems Support Corp.

Citations: 803 F. Supp. 487; 25 U.S.P.Q. 2d (BNA) 1614; 1992 U.S. Dist. LEXIS 16139; 1992 WL 297641Docket: Civ. A. 88-0033-S

Court: District Court, D. Massachusetts; October 9, 1992; Federal District Court

Narrative Opinion Summary

In a protracted litigation between Data General Corporation and Grumman Systems Support Corporation, the central issue revolves around allegations of copyright infringement and trade secret misappropriation concerning Data General's ADEX software. Grumman filed a belated motion to dismiss, asserting that Data General's inability to produce the original source code undermined its claims. The court denied this motion, citing Grumman's delay in pursuing this line of defense despite being aware of the source code's unavailability. The court reiterated that Data General need not produce the original source code to establish infringement; instead, demonstrating ownership and unauthorized copying suffices under copyright law. Grumman's reliance on precedent from Seiler v. Lucasfilm was deemed inapplicable, as the case did not involve post-infringement copyright acquisition. Procedurally, the court dismissed Grumman's motions to reconsider monopolization claims due to a lack of evidence for exclusionary conduct and denied the exclusion of evidence regarding a former employee's Fifth Amendment invocation. Ultimately, Grumman's various motions were denied, permitting Data General to proceed with its claims as the trial date approached.

Legal Issues Addressed

Admissibility of Evidence

Application: The court permits evidence of George Tasso's Fifth Amendment invocation, rejecting Grumman's objections regarding its relevance and potential prejudice.

Reasoning: Grumman's Motion In Limine to exclude evidence of George Tasso's Fifth Amendment invocation is also denied.

Copyright Infringement Requirements

Application: Data General does not need to produce the original source code to prove infringement, as copyright protects the intangible software irrespective of format.

Reasoning: The court clarified that to succeed in a copyright claim, Data General must demonstrate ownership and copying by the defendant, referencing established copyright doctrine.

Motion for Reconsideration

Application: Grumman's motion for reconsideration of monopolization claims is denied due to insufficient evidence of exclusionary conduct.

Reasoning: Grumman's motions to dismiss Data General's copyright infringement and trade secret misappropriation claims are denied, as well as its motion to reconsider monopolization claims based on new case law.

Relevance of Source Code in Copyright Claims

Application: Producing the original source code is not necessary for Data General to support its infringement claim since the object code serves as sufficient evidence.

Reasoning: Data General is not required to produce the original ADEX source code to support its infringement claim.

Timeliness of Motions

Application: The court denies Grumman's request to consider the late-filed motion due to insufficient diligence in addressing the source code issue promptly.

Reasoning: The court denies Grumman's request to consider the late-filed motion, determining that Grumman did not act promptly upon learning of the missing source code.