News & Analysis as of

Motion To Strike

Epstein Becker & Green

Eleventh Circuit Allows Qui Tam Relators to Avoid Complaint Dismissal by Using Information Obtained in Discovery

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The U.S. Court of Appeals for the Eleventh Circuit held in United States ex rel. Sedona Partners LLC v. Able Moving and Storage Inc., No. 22-13340 (11th Cir. Jul. 25, 2025), that while a district court has the discretion to...more

Jenner & Block

Client Alert: An Erie October Surprise: Ninth Circuit Rules Anti-SLAPP Denials Not Immediately Appealable

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On October 9, 2025, in Gopher Media LLC v. Melone, the Ninth Circuit Court of Appeals overruled precedent established over 20 years ago in Batzel v. Smith by unanimously holding, in an en banc decision by 11 judges, that...more

ArentFox Schiff

Ninth Circuit Relaxes Pleading Standard for DTSA Claims

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On August 12, the Ninth Circuit in Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc. held that the Defend Trade Secrets Act (DTSA) does not require a plaintiff to identify its allegedly misappropriated trade secrets with...more

Fenwick & West LLP

No Fast SLAPP for This Gopher: Ninth Circuit Says Wait for the Whole Pie

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District court orders denying motions to strike under California’s anti-SLAPP statute are not immediately appealable under the collateral order doctrine, according to a significant Ninth Circuit ruling that overturned its...more

Saul Ewing LLP

Ninth Circuit Says Denials of California Anti-SLAPP Motions Are Not Immediately Appealable, Reversing Precedent on Free Speech...

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In a reversal of precedent, the U.S. Court of Appeals for the Ninth Circuit held that parties cannot immediately appeal denials of California Anti-SLAPP ("Strategic Lawsuit Against Public Participation") motions under the...more

Davis Wright Tremaine LLP

Ninth Circuit Removes Right to Immediate Appeal From Denials of California Anti-SLAPP Motions, Preserving Use of SLAPP Statute in...

On October 9, 2025, an en banc Ninth Circuit panel unanimously held that the denial of a special motion to strike under California's anti-SLAPP statute is no longer immediately appealable in the Ninth Circuit under the...more

King & Spalding

Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc.: The Ninth Circuit Recognizes Limits on Required Pre-Discovery Disclosures for...

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In an order with important implications for trade secret disputes in federal court, on August 12, 2025, the Ninth Circuit Court of Appeals held that a district court abused its discretion in striking a plaintiff’s trade...more

McDermott Will & Schulte

No specifics, no case? DTSA trade secret disclosure timing differs from CUTSA

The US Court of Appeals for the Ninth Circuit found that a district court abused its discretion by striking several of the plaintiff’s trade secrets, concluding that the court improperly relied on Rule 12(f) and failed to...more

White & Case LLP

Ninth Circuit Relaxes Standard for Pleading Federal Trade Secrets Claims in California

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In California trade secrets cases, parties almost always fight about the scope of alleged trade secrets because a state statute requires identification of secrets “with reasonable particularity” before discovery. But in...more

Bennett Jones LLP

BC Court Rules Class Action Plaintiffs Cannot Delay Pre-Certification Applications if the Plaintiff Has Not Applied for...

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When faced with defendants' applications brought before the plaintiff's application to certify a class proceeding, BC courts have often held that there is a presumption that certification will proceed first. In that context,...more

Akin Gump Strauss Hauer & Feld LLP

Patent Damages Based on Avoided Costs Do Not Invoke the Entire Market Value Rule

In ruling on a recent motion to strike, a judge in the Eastern District of Texas permitted a damages expert to rely on a damages theory based on defendant’s “avoided costs,” holding that this theory did not run afoul of the...more

Goldberg Segalla

Court Grants Boiler Manufacturer’s Motion to Strike Punitive Damages Under Maritime Law

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Court: U.S. District Court for the Northern District of California - Plaintiff Vernon Armstrong alleges he developed lung cancer from asbestos exposure during his Navy service, under claims for negligence, strict liability,...more

Marshall Dennehey

Federal Court Dismisses Negligence Claim Against USPS Due to Late Filing and Lack of Evidence

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Allen v. United States, 2025 WL 35468, No. 24-99-KSM (E.D. Pa. Jan. 3, 2025) - A federal court dismissed a negligence claim against the United States Postal Service (USPS) after the plaintiff failed to timely oppose the...more

Zelle  LLP

Federal District Court Holds Engineer Is Qualified Enough, and His Methods Are Reliable Enough, to Testify to Date Wind and Hail...

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In Wings Platinum, LLC v. Westchester Surplus Lines Ins. Co., No. 3:23-CV-2145-D, 2025 WL 391388 (N.D. Tex. Feb. 4, 2025), a federal district court recently held that an engineer with one year and one month of experience...more

Blake, Cassels & Graydon LLP

Cour d’appel de l’Ontario : Une requête en radiation équivaut à une renonciation au droit à l’arbitrage

Aperçu Dans l’affaire RH20 North America Inc. v. Bergmann, la Cour d’appel de l’Ontario (la « CAO ») a confirmé qu’une requête en radiation de réclamations susceptibles d’être réglées par voie d’arbitrage équivaut à une...more

Blake, Cassels & Graydon LLP

Motion to Strike Waives Right to Arbitrate: Ontario Court of Appeal

Overview - In RH20 North America Inc. v. Bergmann, the Ontario Court of Appeal affirmed that a motion to strike arbitrable claims amounts to a waiver of the right to arbitrate and disentitles the moving party to a stay of...more

Freiberger Haber LLP

The Second Department Reminds Litigants To Follow Requisite Procedures Before Seeking Discovery Sanctions

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Discovery (or disclosure) in litigation, which is governed in New York State practice by Article 31 of the CPLR, is the mechanism by which litigants obtain facts and information from other parties and non-parties to support...more

Patton Sullivan Brodehl LLP

LLC Member Acting for LLC Without Authority Is Not “Protected Activity” Under California’s Anti-SLAPP Statute

California’s anti-SLAPP statute (Code of Civil Procedure section 425.16) aims to protect defendants from meritless lawsuits designed to chill “protected activity” — i.e., the exercise of rights of petition (litigation) or...more

Fenwick & West LLP

Ninth Circuit to Rehear Appealability of Denied Anti-SLAPP Motions

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The Ninth Circuit has granted a rehearing en banc in Martinez v. ZoomInfo Tech., Inc. concerning the appealability of denial of anti-SLAPP motions under the collateral order doctrine. Historically, the Ninth Circuit has...more

Epstein Becker & Green

California Supreme Court’s Estrada Decision Leaves Employers with a Wide Array of Tools to Attack PAGA Actions – Including Seeking...

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On January 18, 2024, the California Supreme Court issued its much-anticipated decision in Estrada v. Royalty Carpet Mills, resolving a dispute among the appellate courts and concluding that Private Attorneys General Act...more

CDF Labor Law LLP

Cal. Supreme Court Provides Guidance on How to Limit Overbroad PAGA Claims

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On January 18, 2024, the California Supreme Court issued its opinion in Estrada v. Royalty Carpet Mills, Inc., concluding that trial courts do not have inherent authority to strike a PAGA claim on the grounds that it is...more

Littler

California Supreme Court Rules that Trial Courts Lack Inherent Authority to Strike PAGA Claims on Manageability Grounds

Littler on

On January 18, 2024, the California Supreme Court held that trial courts lack inherent authority to strike (dismiss with prejudice) claims under the Private Attorneys General Act of 2004 (PAGA) on manageability grounds. The...more

Stradling Yocca Carlson & Rauth

The Magic Carpet Ride Comes to an End: PAGA Claims Can No Longer Be Stricken on Manageability Grounds

On January 18th, the California Supreme Court in Estrada v. Royalty Carpet Mills, Inc. ruled that defendants sued under the Private Attorney General Act (PAGA) may no longer strike unmanageable claims.  PAGA claims are...more

Proskauer - California Employment Law

Trial Courts May Control, But They May Not Dismiss, PAGA Claims On “Manageability” Grounds

The California Supreme Court has issued its much-anticipated decision in Estrada v. Royalty Carpet Mills, Inc., determining whether Private Attorneys General Act (PAGA) claims can be dismissed as unmanageable. The Court...more

Fox Rothschild LLP

A Publicly Filed Court Document Does Make a Sound, Even if No One is Around to Hear It

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When an amended complaint renders the arguments of a motion to dismiss moot, what effect does it have on the public’s ability to view the parties’ filings on the motion? In Karriker v. Harpoon Holdings, L.P., 2023 NCBC 67,...more

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