Synopsys, Inc. v. InnoGrit, Corp.

I. BACKGROUND

A. Factual Background Synopsys is a provider of electronic design automation (“EDA”). SAC ¶ 8. EDA entails “using computers to design, verify, and simulate the performance of electronic circuits.” Id.

1 InnoGrit’s motion to dismiss the SAC contains a notice of motion that is separately paginated from the memorandum of points and authorities in support of the motion. See Mot. at ii–iv. Civil Local Rule 7-2(b) provides that the notice of motion and points and authorities should be contained in one document with a combined limit of 25 pages. See Civ. Loc. R. 7-2(b). Synopsys has invested substantial sums of money in designing EDA software, and offers a variety of software applications to purchasers. Id. ¶¶ 10, 11. In order to access Synopsys’s software, customers purchase licenses, which grant “customers limited rights to install [Synopsys’s] EDA software and to access and use specific . . . software programs subject to control by [Synopsys] via its license key system.” Id. ¶ 11. Synopsys’s license key system is a “security system that controls access to its licensed software by requiring a…