Viacom Motion To Compel

Electronically FILED by Superior Court of California, County of Los Angeles on 02/28/2020 03:07 PM Sherri R.
Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 PROSKAUER ROSE LLP

ANTHONY J. ONCIDI, SBN 118135
2 aoncidi@proskauer.com
PIETRO A. DESERIO, SBN 309230
3 pdeserio@proskauer.com
COLE D. LEWIS, SBN 323030
4 clewis@proskauer.com
2029 Century Park East, 24th Floor
5 Los Angeles, CA 90067-3010
Telephone: (310) 557-2900
6 Facsimile: (310) 557-2193
7 Attorneys for Plaintiff,

VIACOM INTERNATIONAL INC.
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
10 FOR THE COUNTY OF LOS ANGELES

11 VIACOM INTERNATIONAL INC., a Delaware Case No. 18STCV00496
Corporation,
12 PLAINTIFF VIACOM INTERNATIONAL
Plaintiff, INC.’S NOTICE OF MOTION AND
13 MOTION FOR AN ORDER COMPELLING
vs. DEFENDANT NETFLIX, INC. TO PROVIDE
14 FURTHER RESPONSES TO SPECIAL
NETFLIX, INC., a Delaware Corporation, INTERROGATORIES (SET ONE) AND
15 MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT THEREOF;
16 Defendant. REQUEST FOR SANCTIONS
17
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[filed concurrently with Separate Statement of
19 Items in Dispute; Declaration of Pietro A.
Deserio; Request for Judicial Notice]
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Date: April 27, 2020
21 Time: 8:30 AM
Judge: Hon. Richard E. Rico
22 Dept: 17
23 Reservation ID: 910279936135

Complaint Filed: October 5, 2018
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PLAINTIFF VIACOM INTERNATIONAL INC.’S NOTICE OF MOTION AND MOTION FOR AN ORDER
COMPELLING DEFENDANT NETFLIX, INC. TO PROVIDE FURTHER RESPONSES TO SPECIAL
INTERROGATORIES (SET ONE) AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT
THEREOF; REQUEST FOR SANCTIONS
1 TO DEFENDANT AND ITS ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that on April 27, 2020, at 8:30 a.m., or as soon thereafter as the matter
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may be heard by the Honorable Richard E. Rico, in Department 17 of the Los Angeles Superior Court,
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located at 111 N. Hill Street, Los Angeles, CA 90012, Plaintiff Viacom International Inc. (“Viacom” or
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“Plaintiff”) will, and hereby does, make a motion for an order (1) compelling Defendant Netflix, Inc.
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(“Defendant” or “Netflix”) to serve further responses to Viacom’s Special Interrogatories (Set One); and
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8 (2) imposing monetary sanctions against Netflix, under Code of Civil Procedure Section 2030.300, in an
9 amount not less than $6,000, which amount represents the attorneys’ fees and costs incurred by Viacom
10 in bringing this Motion.
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This Motion will be and is made upon the ground that Netflix has failed and refused to provide
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discovery and instead interposed objections that are without merit or substantial justification.
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This Motion will be and is based upon this Notice, the attached Memorandum of Points and
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15 Authorities and Declaration of Pietro A. Deserio, the accompanying Separate Statement, the Request for
16 Judicial Notice, California Code of Civil Procedure sections 2030.300 et seq., California Rules of Court,
17 Rule 3.1345, the papers, pleadings and records on file herein and the argument of counsel.
18 Dated: February 28, 2020 PROSKAUER ROSE LLP
Anthony J. Oncidi
19 Pietro A. Deserio
Cole D. Lewis
20
21 By:
22 Anthony J. Oncidi

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1
2 TABLE OF CONTENTS
3 Page
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TABLE OF CONTENTS ................................................................................................................. II
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I. INTRODUCTION ................................................................................................................... 1
6 II. BACKGROUND ..................................................................................................................... 2
7 A. The Complaint ..................................................................................................................2
8 B. Netflix Refuses to Produce Relevant Interrogatories and Instead Stands Behind
Two Baseless Objections. .................................................................................................3
9 III. ARGUMENT ........................................................................................................................... 4
10 A. Viacom’s Motion To Compel Should Be Granted Because Netflix’s Baseless
Objections To The Interrogatories Are Without Merit. .....................................................4
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1. The Requested Information is Relevant Because it Directly Evidences
12 The Harm to Viacom Attributable to Netflix’s Unfair Competition. ...................5
13 2. The Value of the Requested Information is Not Outweighed By

Privacy Concerns Because Each Interrogatory Requests a Single
14 Numerical Figure that Will be Adequately Protected by the Parties’
Protective Order. ...................................................................................................7
15 B. Monetary Sanctions Should Be Imposed Against Netflix Because Their
Objections Are Without Substantial Justification and They Have Obstructed
16 Discovery. .........................................................................................................................9
17 IV. CONCLUSION ........................................................................................................................ 9
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- ii -
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I. INTRODUCTION
3 In this action, Viacom International Inc. (“Plaintiff” or “Viacom”) is bringing a claim against
4 Defendant Netflix, Inc. (“Defendant” or “Netflix”) for unfair competition pursuant to Cal. Bus. & Prof.
5
Code §§ Code 17200 et seq., as well as a claim for tortious interference. Viacom seeks an injunction
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tailored to end Netflix’s blatant disregard for enforceable employment contracts. Netflix has sought out
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and aggressively pursued several Viacom employees while they were under a term employment
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agreement with Viacom (including Momita SenGupta, an ex-Viacom employee who is the subject of
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10 Viacom’s tortious interference claim). Netflix promises to continue the same behavior if not enjoined
11 by this Court.1 Netflix, in its brazen attempt to justify interfering with the enforceable term contracts of
12 employees of its direct competitors, alleges that Viacom’s contracts contain “illegal provisions” that
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infect the entire agreement. Netflix also asserts that to the extent Viacom has entered into successive
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term contracts with an employee that cumulatively exceed 7 years, such contracts are voidable (by the
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employee) under Labor Code Section 2855. Notwithstanding that no California court has ever validated
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17 Netflix’s legal position – and that this Court has expressly rejected those same arguments in the Fox v.
18 Netflix case – Netflix remains steadfast in its resolve to steal employees from competitors regardless of
19 whether those employees are subject to enforceable fixed-term employment agreements. Viacom simply
20 seeks to hold Netflix accountable for, and prevent, its unlawful poaching of Viacom’s employees.
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This Motion is necessary because Netflix refuses to provide discovery in response to four
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targeted and highly relevant Special Interrogatories served by Viacom. Netflix’s objections are without
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substantial justification and its purported privacy concerns are simply an excuse to deprive Viacom of
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27 On December 10, 2019, this Court enjoined Netflix from poaching employees from another media
company (Fox) under similar circumstances, using this same unlawful activity, and with the same
28 blatant disregard for the law. See Request for Judicial Notice, Ex. A.
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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR AN ORDER
COMPELLING DEFENDANT TO PROVIDE FURTHER RESPONSES AND AWARDING SANCTIONS
1 information directly relevant to the damage and/or injury Viacom has incurred as a result of Netflix’s
2 unlawful poaching of Viacom employees.
3
As part of the damages and/or injury Viacom has suffered, Viacom intends to submit evidence
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regarding the lost value to Viacom of the employees it lost to Netflix—who were subject to fixed-term
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employment contracts—due to Netflix’s illegal poaching activities. In order to demonstrate the lost
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7 value, Viacom seeks reasonably limited and specifically targeted discovery regarding the compensation
8 paid by Netflix to the group of former Viacom employees who were subject to fixed-term employment
9 contracts with Viacom and who were induced by Netflix to leave Viacom and join Netflix before the
10 expiration of their Viacom contracts. The compensation paid by Netflix to those employees will help
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establish the market value of the individuals and, more importantly, will show the difference in the
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market value and the rates of pay between the “market value” paid by Netflix and the compensation that
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Viacom was contractually obligated to pay the employees. That difference in compensation will be at
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15 least equal to the loss of value suffered by Viacom and misappropriated by Netflix as a result of its
16 illegal activities.
17 As discussed herein, the discovery Viacom seeks is directly relevant to Viacom’s unfair
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competition claim and must be produced. There is no valid objection upon which Netflix can rely to
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justify its obstinate refusal to produce such information. Any privacy concerns can be allayed by
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marking the material “Highly Confidential” pursuant to the Protective Order entered into by the parties.
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Accordingly, Netflix should be sanctioned in an amount not less than $6,000, which sum represents the
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23 reasonable attorneys’ fees incurred by Viacom in bringing this motion.
24 II. BACKGROUND
25 A. The Complaint
26 On October 5, 2018, Viacom filed a complaint in Los Angeles Superior Court against Netflix,
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alleging intentional interference with contractual relations and unfair competition pursuant to Cal. Bus.
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1 & Prof. Code §§ Code 17200 et seq. (the “Complaint”). As described in the Complaint, this action arises
2 from Netflix’s inducing a former Viacom employee, Momita SenGupta (“SenGupta”) to breach her term
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employment agreement with Viacom and become employed by Netflix before the expiration of that
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agreement. Netflix, acting in league with SenGupta, plotted for months to breach her employment
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agreement, as part of its unlawful scheme to interfere with fixed-term employment agreements between
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7 Viacom and certain of its highly-valued employees.
8 B. Netflix Refuses to Produce Relevant Interrogatories and Instead Stands Behind Two
9 Baseless Objections.
10 On November 14, 2019, Viacom served Special Interrogatories (Set Three) (the “Special
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Interrogatories”) upon Netflix. See Declaration of Pietro A. Deserio (“Deserio Decl.”), Ex. A. The
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Special Interrogatories requested that Netflix state the total compensation paid to each one of four ex-
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Viacom employees whom Netflix induced to breach their employment contracts with Viacom, from the
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15 date in which the employee left Viacom to the date in which he or she was contractually obligated to
16 work for Viacom. Id. Specifically, the requests asked Netflix to: “State the total compensation YOU
17 paid to [the former employee], INCLUDING bonuses, incentives, and any other form of compensation,
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from [date employee breached the contract] to [date the contract ended].” 2
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On December 17, 2019, Netflix served Objections to Viacom’s Special Interrogatories, objecting
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to each Interrogatory on the basis that it was irrelevant and called for information protected by the
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constitutional right to privacy. See Deserio Decl., Ex. B.
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23 On January 29, 2020, Viacom e-mailed Netflix and explained its position as to why the
24 compensation information sought by the Special Interrogatories was relevant. Viacom requested an
25 extension to move to compel until February 21, 2020. See Deserio Decl., Ex. C. On January 31, 2020,
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28 All four interrogatories are the same, save for (1) the employee’s name; (2) the date the employee
breached the contract; and (3) the date the contract ended. See Deserio Decl., Ex. A.
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1 Netflix asked Viacom to provide more explanation as to why the compensation information sought was
2 relevant and conditioned an extension on Viacom’s granting of a separate extension relating to a
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separate discovery dispute. See Deserio Decl., Ex. D. That same day, Viacom confirmed the mutual
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extensions and inquired about Netflix’s availability to meet and confer. See Deserio Decl., Ex. E.
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On February 14, 2020, the parties met and conferred by phone. The parties could not reach a
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7 compromise regarding the Special Interrogatories. Viacom suggested participating in an informal
8 discovery conference with the Court, but Netflix insisted that formal motion practice was necessary. The
9 parties agreed to extend Viacom’s motion to compel date to February 28, 2020. See Deserio Decl., Ex.
10 F.
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Netflix’s continued refusal to provide discovery and insistence on standing behind bloated
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objections demonstrates bad faith and direct contravention of Netflix’s discovery obligations. Netflix
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should not be permitted to continue withholding four rather limited pieces of information that Viacom is
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15 clearly entitled to under the Code of Civil Procedure—information that is plainly relevant to the
16 damages calculation for Viacom’s unfair competition claim and that is reasonably calculated to lead to
17 the discovery of further admissible evidence.

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III. ARGUMENT
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A. Viacom’s Motion To Compel Should Be Granted Because Netflix’s Baseless
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Objections To The Interrogatories Are Without Merit.
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Netflix’s refusal to provide discovery relating to Viacom’s damages is nothing more than a
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blatant attempt to avoid providing Viacom with the information and documents clearly pertinent to this
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24 matter and, specifically, to the unfair competition claim. Netflix has asserted two baseless objections to
25 four of Viacom’s Special Interrogatories – all asking for the same information for different individuals.
26 For example, Special Interrogatory No. 1 asks Netflix to “State the total compensation YOU paid to Phil
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Rynda, INCLUDING bonuses, incentives, and any other form of compensation, from January 5, 2018 to
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1 March 20, 2018.” Phil Rynda is a former Viacom employee whom Netflix induced to breach his contract
2 in order to work for Netflix. Mr. Rynda breached his employment agreement with Viacom on or about
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January 5, 2018 by resigning his position with Viacom in breach of his employment agreement. Mr.
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Rynda was contractually obligated to continue to work for Viacom up to and including March 20, 2018.
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Viacom propounded three identical interrogatories for employees James Kukucka, Megan Casey, and
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7 Robert Natter – all former Viacom employees whom Netflix induced to breach their employment
8 agreements.
9 Netflix objects that the Special Interrogatories seek information not relevant to any claim or
10 defense in this action and not reasonably calculated to lead to the discovery of admissible evidence.
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Netflix also objects on privacy grounds. For the reasons below, these objections are without merit and
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were interposed without substantial justification.
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1. The Requested Information is Relevant Because it Directly Evidences The
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Harm to Viacom Attributable to Netflix’s Unfair Competition.
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Viacom is entitled to discovery regarding all potential damages and/or injury that flows from
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Netflix’s intentional interference with contracts between Viacom and its employees. This information is
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“relevant to the subject matter involved in the pending action.” Cal. Code Civ. Proc. § 2017.010. See
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19 Puerto v. Superior Court, 158 Cal. App. 4th 1242, 1250 (2008) (“Matters sought are properly
20 discoverable if they will aid in a party’s preparation for trial.” (internal quotation marks omitted)).
21 As a part of its unfair competition claim and in support of its injunction, Viacom must show
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injury from Netflix’s unfair competition. Cal. Bus. & Prof. Code § 17204. Netflix induced at least five
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Viacom employees to breach their contracts by resigning their positions with Viacom before the end of
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each employee’s applicable term of employment. In doing so, Netflix offered, and presumably paid,
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compensation to these employees that is what Netflix itself refers to as “Top of Personal Market” or
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1 “Personal Top of Market.” 3 According to its Person Most Qualified
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Thus, the compensation that each of the four employees received from Netflix will
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show Netflix’s evaluation of each employee’s “Top of Personal Market” as an at-will employee – or in
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other words, the floor of that employee’s value to Netflix. Viacom, on the other hand, does offer fixed-
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7 term contracts and did provide such fixed-term contracts to the four employees who are the subjects of
8 the interrogatories at issue. In exchange for the security provided to the employee of knowing that he or
9 she will have secured ongoing employment for a specified period of time (which most Netflix
10 employees do not have), the employee may be willing to agree to less annual compensation than he or
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she could otherwise earn in an employment-at-will environment (i.e. in the market). Thus, Viacom
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received value in exchange for its promise to employ an individual for a fixed period of time, in the form
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of paying the employee a known, fixed sum (potentially below market value) for his or her contributions
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15 to Viacom during the term. That difference between the value of the employee’s contract at Viacom and
16 what Netflix assesses as the employee’s “Personal Top of Market” value is at least one essential measure
17 of Viacom’s injury attributable to Netflix’s unfair competition. Because Netflix illegally induced the
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employees to breach their contracts, Viacom lost that value and Netflix gained it.
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In order to approximate that lost value to Viacom, there is one easily identifiable figure which
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can be used to demonstrate that value – what Netflix unilaterally determined the employee was worth –
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which is reflected in the overall compensation that Netflix has paid to the four employees in question
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23 since they left Viacom and began employment with Netflix. For example, if Netflix believed that
24 Employee X was worth $1,000,000 per year on an at-will basis and that same employee had signed a
25 multi-year contract with Viacom at $800,000 per year in exchange for the stability associated with stable
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27 Netflix refers to this in their so-called “Culture Memo,” which is available online at
https://jobs.netflix.com/culture; as well as their Work Life Philosophy page available online at
28 https://jobs.netflix.com/work-life-philosophy.
4
See Deserio Decl., Ex. G.
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1 and predictable ongoing employment for a term of years, Viacom would realize at least $200,000 per
2 year of value with its use of fixed-term contracts with that employee, which Viacom lost as a result of
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Netflix’s illegal poaching. Consequently, the information requested by these Interrogatories is not only
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relevant, it is absolutely essential to obtain in order for Viacom’s expert witnesses to prepare a proper
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evaluation of Viacom’s unfair competition claim. Netflix’s relevance objection is baseless. 5
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7 2. The Value of the Requested Information is Not Outweighed By Privacy

Concerns Because Each Interrogatory Requests a Single Numerical Figure
8
that Will be Adequately Protected by the Parties’ Protective Order.
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For Netflix to refuse to produce the four numbers based upon a privacy concern, it must
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establish: (1) a legally protected privacy interest; (2) an objectively reasonable expectation of privacy in
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the given circumstances; and (3) a threatened intrusion that is serious. Williams v. Superior Court, 3 Cal.
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13 5th 531, 552 (2017). A court can then balance the need for the information and countervailing interests
14 in the information, as well as protective measures (like here) that would diminish the loss of privacy. Id.
15 at 84.
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Here, four employees’ privacy interests in their compensation information for a fixed-period of
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time (which can be produced pursuant to a protective order and protected with the highest level of
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security provided for in the order) does not outweigh Viacom’s legitimate interests in obtaining the
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information. All of these employees were formerly contracted with Viacom and breached their
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21 agreements to work for Netflix as a result of Netflix’s unfairly competitive activities. Viacom does not
22 seek documents that evidence compensation information, a breakdown of each component included in
23 each individual’s compensation, or the compensation that the individuals are currently earning. Instead,
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Viacom seeks only the compensation amount (a single number) for the period in which the employee
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26 5
Furthermore, Netflix’s positions regarding discovery are inconsistent. It produced without
27 objection all compensation information relating to Momita SenGupta – a specific employee referenced
in Viacom’s tortious interference with contractual relations claim. To the extent Ms. SenGupta’s
28 compensation is arguably relevant to the action, so is the compensation information relating to other
employees whom Netflix similarly poached in an unlawful manner during the relevant period of time.
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1 would have been providing services to Viacom but for Netflix’s unlawful interference. Netflix must be
2 ordered to produce such discrete information.
3
A 2007 case, SHC Servs., Inc. v. All Health Servs., No. 106CV0761AWIDLB, 2007 WL 430657
4
(E.D. Cal. Feb. 6, 2007) is particular instructive. In SHC, a health service employer, SHC Services, Inc.
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(“SHC”) filed a lawsuit against three former employees and their new employer for intentional
6
7 interference with contractual relations and unfair competition, among other things. Just like in this case,
8 SHC alleged that its direct competitor, All Health Services Corporation (“All Health”), induced three of
9 SHC’s employees to breach their fixed-term employment agreements and work for All Health. Just like
10 in this case, SHC propounded discovery seeking other former employees’ (not just the individual
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defendant employees’) various forms of compensation with All Health. All Health objected based upon
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privacy rights and relevancy. Id. at *2. The Court overruled All Health’s objections and ordered it to
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produce responsive documents relating to the employees’ forms of compensation pursuant to an
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15 attorneys-eyes-only provision of the Stipulated Protective Order. Id.
16 Here, Netflix’s employees’ privacy rights are implicated even less than in SHC, as Viacom only
17 seeks narrow, singular amounts of compensation – not even the documents themselves which would
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evidence the compensation. Like the defendant-employer in SHC, Netflix should be required to produce
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the compensation information.
20
Furthermore, many courts have held that privacy rights associated with compensation
21
information can be adequately protected by a protective order. See IP Glob. Investments Am., Inc v.
22
23 Body Glove IP Holdings, LP, No. CV176189ODWAGRX, 2018 WL 5880137, at *3 (C.D. Cal. Aug. 3,
24 2018) (“The need for discovery to ensure the truth-finding function of litigation, an important public
25 policy interest, far outweighs any privacy interest in [compensation information]”); Luck v. University of
26
San Diego, No. 13CV3088 JLS (BGS), 2014 WL 12461323, at *4 (S.D. Cal. Sept. 15, 2014); Aug. v.
27
Provident Life & Acc. Ins., Co., No. 2:09-CV-01951-DMG-SH, 2010 WL 8056576, at *11 (C.D. Cal.
28
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1 Nov. 16, 2010).
2 Unless and until Netflix is ordered to comply with these reasonably drafted and specifically
3
targeted discovery requests, which are clearly calculated to lead to the discovery of admissible evidence,
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Viacom cannot assess the true extent of injury suffered by Viacom.
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B. Monetary Sanctions Should Be Imposed Against Netflix Because Their Objections
6
7 Are Without Substantial Justification and They Have Obstructed Discovery.
8 A court “shall impose a monetary sanction . . . against any party, person, or attorney who
9 unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that
10 the one subject to the sanction acted with substantial justification or that other circumstances make the
11
imposition of the sanction unjust.” Cal. Civ. Proc. Code § 2030.300(d). Netflix’s continued
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withholding of clearly discoverable information crucial to Viacom’s damages analysis is in bad faith and
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without any—let alone substantial—justification. Netflix has obstructed discovery by refusing to
14
15 substantively respond to Viacom’s narrow interrogatories at issue. Therefore, the Court should impose
16 monetary sanctions against Netflix, in an amount not less than $6,000, which amount represents the
17 attorneys’ fees and costs incurred by Viacom in bringing this motion. See Deserio Decl., ¶¶ 9-13.
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IV. CONCLUSION
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For these reasons, Viacom respectfully requests that Viacom’s Motion for an Order Compelling
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Netflix to Provide Further Responses to Special Interrogatories (Set One) and Awarding Monetary
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Sanctions is granted.
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Dated: February 28, 2020 PROSKAUER ROSE LLP
23 Anthony J. Oncidi
Pietro A. Deserio
24 Cole D. Lewis
25
26
By: ~ --
Anthony J. Oncidi
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Journal Technologies Court Portal
Court Reservation Receipt

Reservation
Reservation ID: Status:
910279936135 RESERVED
Reservation Type: Number of Motions:
Motion to Compel Further Discovery Responses 1
Case Number: Case Title:
18STCV00496 VIACOM INTERNATIONAL INC vs NETFLIX, INC.
Filing Party: Location:
Viacom International Inc (Plaintiff) Stanley Mosk Courthouse - Department 17
Date/Time: Con rmation Code:
April 27th 2020, 8:30AM CR-E6UQCM32RTAJRZXSO
Fees
Description Fee Qty Amount
Motion to Compel Further Discovery Responses 60.00 1 60.00
Credit Card Percentage Fee (2.75%) 1.65 1 1.65
TOTAL $61.65
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Amount: Type:
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Account Number: Authorization:
XXXX6918 03313I
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Electronically FILED by Superior Court of California, County of Los Angeles on 02/28/2020 03:07 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk

1 PROSKAUER ROSE LLP

7 Attorneys for Plaintiff,

10 FOR THE COUNTY OF LOS ANGELES

23 Reservation ID: 910279936135

23 Attorneys for Plaintiff,

13 2. The Value of the Requested Information is Not Outweighed By

23 reasonable attorneys’ fees incurred by Viacom in bringing this motion.

7 Viacom and certain of its highly-valued employees.

7 compromise regarding the Special Interrogatories. Viacom suggested participating in an informal

17 the discovery of further admissible evidence.

7 2. The Value of the Requested Information is Not Outweighed By Privacy

15 attorneys-eyes-only provision of the Stipulated Protective Order. Id.

7 Are Without Substantial Justification and They Have Obstructed Discovery.

Court Reservation Receipt

Motion to Compel Further Discovery Responses 60.00 1 60.00

Credit Card Percentage Fee (2.75%) 1.65 1 1.65

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