{"id":322,"date":"2026-01-05T12:00:00","date_gmt":"2026-01-05T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=322"},"modified":"2026-01-05T12:00:00","modified_gmt":"2026-01-05T12:00:00","slug":"oracle-procore-trade-secret-disclosure-discovery","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=322","title":{"rendered":"Oracle v. Procore \u2014 N.D. Cal. magistrate refines trade-secret disclosure and discovery scope"},"content":{"rendered":"
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Case<\/dt>\n
Oracle America, Inc., et al. v. Procore Technologies, Inc., et al.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Northern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-05<\/dd>\n
Docket No.<\/dt>\n
4:24-cv-07457<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Defend Trade Secrets Act; trade-secret particularity; discovery; financial information; text messages from personal devices; California construction software<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

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.<\/p>\n

Oracle\u2019s 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\u2019s 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\u2019s iCloud, Google Drive, and personal devices).<\/p>\n

The parties brought four bundled discovery disputes to Magistrate Judge Laurel Beeler in the run-up to early-January 2026 depositions: Procore\u2019s motion to compel more particularized trade-secret disclosures, Oracle\u2019s motion for broader Procore financial information, and the sufficiency of Procore\u2019s responses to several interrogatories.<\/p>\n

The Court’s Holding<\/h2>\n

The court denied Procore\u2019s motion to compel more particularized trade-secret disclosures. Oracle\u2019s file-by-file identification, with category labels, contents, and locations of where the files were found on Mariano\u2019s and Procore\u2019s 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.<\/p>\n

The court granted Oracle\u2019s 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.<\/p>\n

On the interrogatories, the court ordered targeted supplementation. Procore must supplement Interrogatory No. 9 (Mariano\u2019s involvement and the related customer\/revenue information) by January 7, 2026, consistent with the broader financial-discovery ruling. The court found Procore\u2019s investigation-related response under Interrogatory No. 5 sufficient given Procore\u2019s representation of completeness, with a duty to supplement if warranted. As to Interrogatory No. 7 \u2014 the storage-devices interrogatory and the related text-message dispute \u2014 the interrogatory response itself was adequate; the live issue was whether Procore had searched its employees\u2019 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\u2019 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\u2019s phone to guide further productions.<\/p>\n

Key Takeaways<\/h2>\n