In Young v. Salesforce, Inc., No. 22-cv-09067-JST (LB) (N.D. Cal. June 30, 2025), California Magistrate Judge Laurel Beeler denied plaintiffs’ request for source code discovery, but ordered Salesforce to “disclose all relevant Chat-related hyperlinked material about functionality and architecture.”

Case Discussion and Judge’s Ruling

In this case, the parties disputed whether the plaintiffs are entitled to the source code for Salesforce Chat. Chat, an application-programming interface — prewritten code enabling customers to build functions into their programs — is configured by those customers (like Rite Aid and Kaiser), who control the data.

The plaintiffs argued that the source code would reveal how Chat routes communications and Salesforce uses the data. Salesforce countered that Chat’s functionality — not its code — was relevant, it provided discovery about its software architecture and capabilities, and the plaintiffs sent their Rule 30(b)(6) topics, which will illuminate the issues. Salesforce also contended that disclosing proprietary source code risks competitive harm in Saleforce’s software-as-a-service market.

Judge Beeler stated: “On this record, discovery is disproportionate. Salesforce’s documents and proposed depositions offer less burdensome alternatives to understanding Chat’s functionality…The plaintiffs cite cases where source code was disclosed, but all involve the voluntary production of source code…Courts authorize alternatives like documents, diagrams, and testimony as less burdensome, proportional alternatives to source-code disclosure.”

However, Judge Beeler also stated: “Regarding hyperlinked documents, Salesforce need not produce publicly available material but must disclose all relevant Chat-related hyperlinked material about functionality and architecture. The plaintiffs must specify any disputed hyperlinks, and the parties must meet and confer to resolve disputes, per the court’s standing order”.

So, what do you think? Are you more surprised that the Court denied source code discovery or that it ordered disclosure of “all” Chat-related relevant hyperlinked material? Please share any comments you might have or if you’d like to know more about a particular topic.

Case opinion link courtesy of Minerva26, an Affinity partner of eDiscovery Today.

Disclaimer: The views represented herein are exclusively the views of the author, and do not necessarily represent the views held by my employer, my partners or my clients. eDiscovery Today is made available solely for educational purposes to provide general information about general eDiscovery principles and not to provide specific legal advice applicable to any particular circumstance. eDiscovery Today should not be used as a substitute for competent legal advice from a lawyer you have retained and who has agreed to represent you.