SanMedica International, LLC v. Ghattas

Summary

The United States District Court for the District of Utah granted the plaintiffs’ motion to compel nonparty Izak Rock to comply with a Rule 45 subpoena seeking documents concerning alleged counterfeit sales through an eBay account. The court found the requested information relevant and proportional and ordered production by April 27, 2026, or another mutually agreed date, but denied the plaintiffs’ request for attorney’s fees.

Holdings

1. The subpoena sought relevant and proportional information because it concerned the alleged counterfeit sales through the utah-distro eBay account, which were central to plaintiffs' claims.
2. The subpoena did not impose an undue burden on Rock, and Rock was required to comply and produce responsive documents.
3. Plaintiffs were not entitled to attorney's fees on this motion to compel.

Questions Presented

1. Whether the subpoena sought information within the scope of discovery under Federal Rule of Civil Procedure 26(b)(1).
2. Whether compliance with the subpoena imposed an undue burden on the nonparty under Federal Rule of Civil Procedure 45.
3. Whether plaintiffs were entitled to attorney's fees for prevailing on the motion to compel.

Disposition

other