Judge: Stephen I. Goorvitch, Case: 21STCV02371, Date: 2023-05-24 Tentative Ruling

Case Number: 21STCV02371    Hearing Date: February 15, 2024    Dept: 39

Brink Biologics, Inc. v. Sanofi, S.A., et al.

Case No. 21STCV02371

Motion for Leave to Amend

 

Plaintiff Brink Biologics, Inc. (“Plaintiff”) filed this action against Sanofi, S.A. (“Sanofi”), Sanofi-Aventis U.S., LLC (“SAUS”), and Sanofi-Aventis Recherche & Developpement, S.A. (“SARD”) (collectively, “Defendants”).  Conkwest Incorporated (“Conkwest”), a predecessor entity of Plaintiff, entered into a non-exclusive licensing agreement with SARD on December 16, 2011.  Plaintiff alleges that this agreement granted Defendants a license to use NK-92 cells for research and development purposes.  Plaintiff alleges that Defendants were not authorized to modify the cells or use the cells for commercial purposes, like potency or quality control release assays.  Plaintiff alleges that Defendants violated both prohibitions, as a result of which Plaintiff terminated the license on January 19, 2021.  Defendants filed a cross-complaint against Plaintiff stemming from this termination.  Now, Plaintiff seeks to file a first amended complaint.

 

Under Code of Civil Procedure section 473, subdivision (a)(1), “The court may, in furtherance of justice, and on any terms as may be proper, allow a party to amend any pleading or proceeding by adding or striking out the name of any party, or by correcting a mistake in the name of a party, or a mistake in any other respect; and may, upon like terms, enlarge the time for answer or demurrer. The court may likewise, in its discretion, after notice to the adverse party, allow, upon any terms as may be just, an amendment to any pleading or proceeding in other particulars; and may upon like terms allow an answer to be made after the time limited by ther code.”  The Court has wide discretion to allow either party to amend pleadings “upon any terms as may be just.”  (See Code Civ. Proc., § 473, subd. (a)(1).)  Judicial policy favors resolution of all disputed matters between the parties and, therefore, leave to amend is liberally granted.  (Berman vs. Bromberg (1986) 56 Cal.App.4th 936, 945.)  “[I]t is an abuse of discretion for the court to deny leave to amend where the opposing party was not misled or prejudiced by the amendment.”  (Kittredge Sports Co. v. Superior Court (1989) 213 Cal.App.3d 1045, 1048.)

 

Defendants’ counsel cites Plaintiff’s delay in seeking this amendment.  However, delay alone is not a basis for denial of Plaintiffs’ motion.  (Higgins v. Del Faro (1981) 123 Cal.App.3d 558, 564-565.)  Defendants must show that Plaintiffs’ delay prejudiced Defendants to justify denial of the motion.  (See Hirsa v. Superior Court (1981) 118 Cal.App.3d 486, 490.)  The Court grants the motion on the condition that new discovery is limited to that which is not duplicative of prior discovery and is likely to develop new evidence in support of Plaintiff’s claims.  To that end, the Court ordered Plaintiff’s counsel to file a proposed discovery plan relating to the amendment.  The Court has reviewed the discovery plan and grants the motion on the condition that Plaintiff’s counsel (as well as Defendants’ counsel) may not propound any additional discovery without authorization of the Court.  Specifically, the Court orders as follows:

 

            A.        Special Interrogatories Numbers 1, 2, and 16 through 25

 

Plaintiff seeks an order requiring Defendants to supplement their responses to Special Interrogatories Numbers 1, 2, and 16 through 25.  There is no basis to do so.  Defendants’ responses were served on October 6, 2021.  None of the issues identified by Plaintiff’s motion clearly occurred after that date.  The mere fact that Plaintiff’s counsel believes Defendants make misrepresentations in their discovery responses is not a basis to order them to supplement the responses.  Plaintiff’s counsel is free to impeach Defendants’ witnesses at trial.  Therefore, the Court denies leave to propound this discovery as a condition of the amendment.   

 

            B.        Requests for Production of Documents

 

Plaintiff seeks “limited additional document discovery,” specifically: (1) Records regarding storage of the NK-92 cells, and (2) Records and communications regarding transfers of the NK-92 cells from Defendants to third parties.  Again, these categories were covered by prior requests for production of documents.  Plaintiff’s counsel previously served Request for Production #1, which requested:

 

“DOCUMENTS sufficient to identify each of YOUR uses (e.g., antibody-dependent

cellmediated cytotoxicity (ADCC) testing, characterization assays, potency assays, quality control testing, stability testing, etc.) of NK-92 CELL LINES RELATING TO NK-92-RELATED COMPOSITIONS, including the nature of such use, the date of such use, the location of such use, the PERSONS involved with such use, the PERSONS who had access to the NK-92 CELL LINES, and the results of such use.”

 

Plaintiff’s counsel previously served Request for Product #17, which requested:

 

“All DOCUMENTS reflecting any COMMUNICATION between YOU and any other PERSON or entity RELATING TO the use of NK-92 CELL LINES.”

 

Plaintiff’s counsel previously served Request for Production #46, which requested:

 

“DOCUMENTS sufficient to identify each transfer of NK-92 CELL LINES, including the identity of the transferor, the identity of the recipient, the date of the transfer, the volume of NK92 CELL LINES that were transferred, and the purpose for which the recipient intended to use the NK92 CELL LINES, if known.”

 

Plaintiff’s counsel previously served Special Interrogatory #19, which requested:

 

            “Identify all locations where you have or someone on your behalf has stored any NK-92 cells from December 16, 2011, to the present.

 

Plaintiff’s counsel does not identify any reason why these responses do not address the issues giving rise to the new claims.  Therefore, the Court denies leave to propound new document requests as a condition of the amendment. 

 

            C.        New Special Interrogatory

 

            Plaintiff seeks to propound a new special interrogatory regarding whether Defendants have ever used the NK-92 cells for ADCC testing with acceptance criteria for any other compounds/biologics other than isatuximab.  This request would be duplicative of the following special interrogatories:

 

            SROG #1 – Explain how you have used or intend to use the NK-92 cells in connection with manufacturing and testing of NK-92 related compounds. 

 

            SROG #16 – Identify every pharmaceutical or biological material or therapeutic agent other than Sarlcisa that you or someone on your behalf has tested or manufacturerd using NK-92 cells from December 16, 2011 to the present.

 

            SROG #17 – Gor each material or agent identified in your response to SROG #16, describe how the NK-92 cells were used.

 

            SROG #18 – For each material or agent identified in your response to SROG #16, identify all documents relating to that use.

 

The mere fact that Plaintiff’s counsel believes Defendants make misrepresentations in their discovery responses is not a basis to order them to supplement the responses.  Plaintiff’s counsel is free to impeach Defendants’ witnesses at trial.  Therefore, the Court denies leave to propound this discovery as a condition of the amendment. 

 

            D.        PMQ Depositions

 

            Plaintiff’s counsel requests PMQ testimony relating to the “subject matter of the amendments to the Complaint, including, but not limited to, any modifications of the NK-92 cells, all uses of the NK-92 cells for other isatuximab, and any uses of the NK-92 cells after Brink terminated the 2011 License on January 19, 2021.”  Plaintiff’s counsel had the opportunity to take depositions on these topics.  Therefore, the Court denies leave to take these depositions as a condition of the amendment.    

 

            E.         Limited Percipient Witness Testimony

 

            Plaintiff’s counsel seeks to take three additional depositions: (1) Laura Geagan, (2) Angela Virone-Oddos, and (3) Florence Attenot.  The Court authorizes these depositions. 

 

            F.         Defendants’ Additional Depositions

 

            Defendants’ counsel seeks to re-take the depositions of Barry Simon, Peter Johnson, Jerald Gnuschkle, and Mark Kokes.  The Court cannot conclude that these depositions are unnecessary.  The interpretation of a contract is a judicial function.  (Wolf v. Walt Disney Pictures & Television (2008) 162 Cal.App.4th 1107, 1126, citation omitted.)  In engaging in this function, the trial court “give[s] effect to the mutual intention of the parties as it existed” at the time the contract was executed.  (Ibid., citing Civ. Code, § 1636.)  Ordinarily, the objective intent of the contracting parties is a legal question determined solely by reference to the contract’s terms.  (Ibid., citing Civ. Code, § 1639.)  However, extrinsic evidence is admissible to interpret an agreement when a material term is ambiguous.  (Ibid., citations omitted.) 

 

            There may be an ambiguity in the parties’ licensing agreement.  The license states that it is a “non-commercial license” that permits Defendants to use the NK-92 cells for “the Purpose” of the license.  The “Purpose” allows Defendants to “develop and/or manufacture the Modified Cell Line for use on Antibody Products by [Defendants] for “[b]atch or quality control release assays for one or more Antibody Products” and “[o]ther research and development purposes pertaining to Antibody Products.”  Yet, another provision of the license states: “The license shall not include the sale of a Commercial Product by [Defendants] or the use of the Cells Lines or Modified Cell Lines for batch or quality control release assays for one or more Antibody Products.”  Plaintiff takes the position that the former language is boilerplate contract language, and the second provision is an “opt out.”  Defendants take the position that the license allowed them to administer batch or quality control release assays in research and development but not commercial settings.  There may be ambiguity associated with this issue because neither explanation is clearly dispositive. 

 

            G.        Costs

 

            Defendants ask the Court to condition the amendment on Plaintiff paying the costs associated with the additional depositions.  The Court declines to do so.

 

CONCLUSION AND ORDER

 

            Based upon the foregoing, the Court orders as follows:

 

            1.         Plaintiff’s motion for leave to file an amended complaint based upon the condition that Plaintiff (and Defendants) may not conduct any discovery unless authorized by the Court.

 

            2.         The Court authorizes only the following discovery: (1) Depositions of Laura Geagan, Angela Virone-Oddos, and Florence Attenot; and (2) Depositions of Barry Simon, Peter Johnson, Jerald Gnuschkle, and Mark Kokes.  All depositions conducted in the United States shall be taken remotely unless the parties stipulate otherwise.  The Court orders the parties to meet-and-confer to discuss when and how to take the depositions of Angela Virone-Oddos and Florence Attenot. 

 

            3.         The Court denies Defendants’ request to order Plaintiff to pay any costs associated with this additional discovery.

 

            4.         Plaintiff’s counsel shall provide notice and file proof of such with the Court.