Mary Pattison v. HP Inc.

Summary

The court resolves two discovery-letter disputes in a putative class action concerning HP Care Pack rebate administration. The court orders HP to provide specified interrogatory responses and produce documents responsive to certain requests for production, subject to a protective order and privilege-log requirements.

Holdings

1. A putative class representative is entitled to reasonable pre-certification discovery identifying members of the proposed class, including contact information and relevant purchase and rebate information.
2. Discovery seeking information about all Care Pack purchasers or purchasers who experienced covered service events was overbroad and need not be answered when the proposed class was limited to purchasers who did not experience a service event.
3. The fact that responsive information is maintained in separate electronic databases and requires cross-referencing does not, without more, establish undue burden sufficient to avoid relevant discovery.
4. Privacy interests in putative class members' contact information did not bar production where the plaintiff demonstrated a legitimate need and the information could be disclosed subject to a protective order.
5. HP was required to search for and produce responsive internal emails concerning customer complaints about Care Pack rebates and rebate-processing delays, including responsive emails in former employees' inboxes to the extent such emails existed.

Questions Presented

1. Whether discovery identifying purchasers who fell within the putative class definition, including their contact information and purchase information, was relevant and discoverable before class certification.
2. Whether HP established undue burden or insufficient data integration to avoid responding to the requested class-member discovery.
3. Whether privacy concerns barred production of putative class members' personally identifying information despite the existence of a stipulated protective order.
4. Whether the disputed requests for information concerning all Care Pack purchasers or purchasers who experienced service events were relevant to the putative class claims.
5. Whether HP was required to search for and produce responsive rebate-related emails, including emails in former employees' inboxes.

Disposition

other