Arconic Corp. v. Novelis Inc. (W.D. Pa. 2022)
Key Insight: The court denied plaintiff’s motion for recusal based on metadata in the court’s orders that suggested that the special master was the author of some of the court’s opinions in the case. Plaintiff claimed the author field on the metadata suggested the special master was the author of the court’s opinions but the court explained how this opinion was wrong. The author field of the metadata for a document created from a template will continue to reflect the name of the person who originally created the document unless that name is changed. The court did not change or remove the author field when using a template document that had previously been prepared in the case but acknowledged going forward it would revise the authorship data on its court orders as needed. Further, the court’s decisions demonstrate that the opinions and orders are those of the court, acting independently of the special master, based on the differences between the court’s decisions and the related R&Rs by the special master.
Nature of Case: Trade Secrets
Electronic Data Involved: Metadata