A California federal judge has refused to toss technology company Celonis' claims accusing software giant SAP of pushing it out of a market for business process analysis services after dismissing a previous version of the allegations.
U.S. District Judge Vince Chhabria on Monday largely denied SAP's motion to dismiss, saying the alleged conduct should not be understood as a legal "refusal to deal," despite a previous ruling that found SAP has no obligation to let competitors access its databases the way they prefer.
Celonis is only challenging SAP's dealings with its own customers, the judge said, and efforts to prevent customers from dealing with rivals do not fall under the refusal-to-deal framework.
"To the extent that the court's prior order suggested otherwise, that was incorrect," Monday's order said. "That said, if discovery reveals evidence showing that certain aspects of SAP's conduct are, in fact, better understood as refusals to deal with Celonis, then analyzing those aspects of SAP's conduct under a refusal-to-deal framework at some later stage might be warranted."
The judge refused to toss a claim accusing SAP of monopolizing a market for data access, saying that although the court has concerns that "data access" may not in fact be a distinct product from SAP's enterprise resource planning software, Celonis has done enough at this stage to survive dismissal.
The order also refused to toss claims for attempted monopolization of a market for "process mining," which involves analyzing data to uncover possible business improvements. The judge said Celonis alleges that SAP has incrementally barred customers from accessing the data needed for that analysis and has withdrawn technical support for customers that refuse to use its own product, Signavio.
"Those allegations alone are enough to satisfy the wrongful conduct and scienter elements of Celonis's attempted monopolization claim," the order said. "And when SAP's alleged course of conduct is considered in its entirety, it becomes even clearer that Celonis has adequately pled anticompetitive conduct."
The case also accuses SAP of predatory pricing because it gives away its process mining tool for free, a practice Celonis also characterizes as an illegal bundle. The order Monday said it is not clear which theory is more appropriate because the allegations about how often Signavio is sold alone are vague, but concluded that it is not necessary to resolve that ambiguity now.
"If Signavio's price is often zero, and if the marginal cost of offering Signavio is above zero, then the inference that Signavio's price is lower than its marginal cost can be readily drawn — regardless of Signavio's exact cost," the order said.
Judge Chhabria did dismiss a tying claim targeting SAP's alleged inclusion of Signavio in its enterprise resource planning software offerings, finding that there was no allegation that SAP coerced customers into accepting the product.
"Had Celonis pled [that] SAP refuses to sell [enterprise resource planning] software to customers who decline to take Signavio, that would likely constitute coercion for the purposes of stating a tying claim," the order said. "But merely alleging that SAP offers Signavio alongside its [enterprise resource planning] program is not enough."
The order also tossed a claim for promissory estoppel and declined to toss claims for false advertising, intentional interference with prospective economic relations and unfair competition.
In a statement Tuesday, a representative for Celonis said the company is pleased the court has "greenlighted virtually all of our claims, in a resounding victory."
"We are moving forward with 10 claims against SAP, which range from monopolization to predatory pricing, false advertising and more," the statement said. "As the case progresses, we will continue to fight to ensure our customers can access their own data freely and work with the technology providers of their choice. This decision marks a critical milestone in our fight to #FreeTheProcess."
SAP is also facing an antitrust case from Teradata accusing it of illegally tying its enterprise resource planning software to its database products in order to block competition from Teradata's analytical database services. The U.S. Supreme Court denied a petition earlier this month from SAP asking to review a ruling that revived that case.
Representatives for SAP did not immediately respond to a request for comment Tuesday.
Celonis is represented by Michael M. Maddigan, Jennifer Fleury, Justin W. Bernick, Anna Kurian Shaw, Lauren B. Cury, Christopher Fitzpatrick and Michael M. Maddigan of Hogan Lovells and Christopher C. Wheeler and Alexis J. Loeb of Farella Braun & Martel LLP.
SAP is represented by David C. Kiernan, Craig E. Stewart, Nathaniel P. Garrett, Tharan Gregory Lanier and Catherine T. Zeng of Jones Day and Ryan P. Phair, Michael F. Murray and Stephen J. McIntyre of Paul Hastings LLP.
The case is Celonis SE et al. v. SAP SE et al., case number 3:25-cv-02519, in the U.S. District Court for the Northern District of California.
Deal Summary
