In FTC v D-Link, Judge Swiftly Sweeps Aside Competing Motions—and Critiques Summary Judgment Practice
"Since federal judicial records indicate that summary judgment is granted in a minority of cases, routinely filing the motion almost certainly increases the overall cost of litigating civil cases in federal court without a net benefit," wrote U.S. District Judge James Donato.
November 06, 2018 at 06:36 PM
3 minute read
In two pages issued Monday—a mere 429 words—the federal judge overseeing a potentially precedent-setting enforcement action involving internet connected devices not only turned back the parties' cross-motions for summary judgment, but managed to offer up some commentary on the often fruitless nature of summary judgment practice.
U.S. District Judge James Donato, who has been overseeing the Federal Trade Commission's case against Taiwan-based computer networking equipment maker D-Link Corp, tossed aside both sides' motions, noting that summary judgment briefing alone had taken up more than 100 pages.
“While sheer size alone is not fatal to a summary judgment motion, the parties' papers demonstrate a panoply of genuine disputes of material fact that will require a trial, and an opportunity to evaluate witness credibility, to properly resolve,” Donato wrote.
In particular, the judge noted that summary judgment wasn't the appropriate vehicle to resolve the competing evidence over the FTC's claims that D-Link misled consumers about the security of the company's wireless routers and internet cameras. Donato also noted that the process was an ineffective means to determine what, if any, appropriate remedy the FTC might have should it prove out its claims against D-Link.
The underlying case has potentially big implications for the IoT industry. Donato ruled last year that the existence of a security flaw alone wasn't enough for the FTC to plead an injury. But he indicated at the time that he would be open to a theory failing to disclose such flaws deceives consumers.
D-Link's counsel, John Vecchione of the Cause of Action Institute in Washington, D.C., didn't immediately respond to an email seeking comment. The company is also represented by S.J. Christine Yang of Fountain Valley, Calif. and counsel at Pillsbury Winthrop Shaw Pittman.
Representatives from the FTC, likewise, didn't respond to an email seeking comment.
Quoting an essay from a fellow federal judge, Donato opened Monday's opinion writing “In days gone by, litigants might have seen a sign at the courthouse advising 'no spittin', no cussin', and no summary judgment.' ”
The judge continued: “ Since federal judicial records indicate that summary judgment is granted in a minority of cases, routinely filing the motion almost certainly increases the overall cost of litigating civil cases in federal court without a net benefit.”
Also on Monday, Donato denied the parties' competing motions to disqualify each others' expert witnesses. The judge wrote that since the case is set to be tried before him as a bench trial early next year, he can “disregard any admitted evidence that it ultimately determines is not sound.”
Read the order:
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