Unreported / Non-Citable
Background
Oracle sued Procore and former Oracle employee Mark Mariano in the Northern District of California, alleging that Mariano kept confidential Oracle source code and integration documents when he left for Procore and that Procore used the materials to build Procore Pay, a construction-industry payment-management service. The complaint asserts trade-secret misappropriation under the federal Defend Trade Secrets Act and breach of contract by Mariano.
Oracle’s suite of products at issue includes its Textura Payment Management (TPM) solution and related ERP integrations. After the trial court (Judge Tigar) held that Oracle’s pleading sufficiently identified the alleged trade secrets, Oracle served initial trade-secret disclosures identifying 174 files in categories such as source code, integration testing, integration plans, and financial data, along with where each file was found (Mariano’s iCloud, Google Drive, and personal devices).
The parties brought four bundled discovery disputes to Magistrate Judge Laurel Beeler in the run-up to early-January 2026 depositions: Procore’s motion to compel more particularized trade-secret disclosures, Oracle’s motion for broader Procore financial information, and the sufficiency of Procore’s responses to several interrogatories.
The Court’s Holding
The court denied Procore’s motion to compel more particularized trade-secret disclosures. Oracle’s file-by-file identification, with category labels, contents, and locations of where the files were found on Mariano’s and Procore’s systems, matched what the trial court had already approved at the pleading stage and is consistent with disclosures other district courts have approved. Demanding more would risk turning a discovery-management mechanism (designed to give defendants notice and to channel discovery) into a premature merits adjudication, and would penalize Oracle for the practical reality that source-code files are most precisely identified by file rather than by paragraph-style description.
The court granted Oracle’s motion to expand financial discovery beyond Procore Pay. Because Mariano was alleged to have worked across product lines and the alleged trade secrets relate to ERP integrations, financial information about Procore Financials and other related products is relevant. Procore may, however, raise burden objections to specific categories.
On the interrogatories, the court ordered targeted supplementation. Procore must supplement Interrogatory No. 9 (Mariano’s involvement and the related customer/revenue information) by January 7, 2026, consistent with the broader financial-discovery ruling. The court found Procore’s investigation-related response under Interrogatory No. 5 sufficient given Procore’s representation of completeness, with a duty to supplement if warranted. As to Interrogatory No. 7 — the storage-devices interrogatory and the related text-message dispute — the interrogatory response itself was adequate; the live issue was whether Procore had searched its employees’ personal devices for Oracle documents and texts to or from Mariano. Reaffirming that a party has custody or control of work-related information on current employees’ personal devices when it has the legal right to demand it, the court directed the parties to address any further deficiencies via RFP 12 and a separate letter brief, with the pending Forensic Neutral review of Mariano’s phone to guide further productions.
Key Takeaways
- In Northern District trade-secret cases, identifying alleged trade secrets by specific file (with category, location of recovery, and source-code or document type) generally satisfies the particularity requirement at the discovery stage, especially where the trial court has already approved similar disclosures at the pleading stage.
- Once a defendant’s products are accused of using misappropriated material, financial discovery is not necessarily limited to the single accused product; courts will allow discovery into related product lines whose financials may bear on damages and use.
- Personal devices of current employees can be within a corporate party’s “control” for discovery purposes when the work-related information on them is something the company has the legal right to demand. Defendants should expect to search employee text messages where misappropriated documents were forwarded.
- Letter-brief discovery practice in the Northern District works best when each interrogatory and RFP is broken out separately. Here, several disputes turned on whether the issue was really an interrogatory response or an underlying production deficiency.
Why It Matters
Oracle’s suit against Procore is a closely watched dispute in the construction-tech sector, where Oracle’s Textura platform and Procore’s payments and financials products have been competing for the same customers. The order does not decide who will win on the merits, but it sets the discovery rules of engagement in ways that materially affect both sides.
For trade-secret plaintiffs, the order is welcome confirmation that file-level disclosures with categories and recovery locations are enough — they do not have to write expository paragraphs about each line of code at the discovery stage. For defendants, the financial-discovery ruling is a reminder that an alleged misappropriator’s “across-product-line” access to corporate systems can drag related products into the case. And for any company facing trade-secret litigation, the text-message ruling underscores that a robust search of employees’ personal communications about the relevant materials is now table stakes — a forensic neutral on the departing employee’s phone is increasingly standard, but counsel should plan parallel custodian collections for current employees too.