Pop Top Corp. v. Rakuten Kobo Inc.

Summary

The Northern District of California denied Rohit Chandra’s motion to quash subpoenas, obtain a protective order regarding interrogatories, quash a judgment debtor examination, and obtain sanctions. The court held that Chandra’s pending Federal Circuit appeal did not automatically stay post-judgment discovery, that he remained a judgment debtor, and that the requested discovery into his personal assets was not shown to be duplicative, irrelevant, or unduly burdensome. The court directed the parties to submit a stipulated protective order concerning Chandra’s bank records.

Holdings

1. A pending appeal does not automatically stay post-judgment discovery, particularly when the judgment debtor has not sought a stay of enforcement or posted a supersedeas bond.
2. Chandra could not avoid post-judgment discovery on the ground that he was a nonparty because the court had added him as a judgment debtor, and that order remained effective while his appeal was pending.
3. Kobo was entitled to broad post-judgment discovery concerning Chandra's personal assets, including third-party bank subpoenas, interrogatories, and a judgment debtor's examination, and the discovery was not shown to be duplicative, irrelevant, or unduly burdensome.
4. Chandra's privacy concerns did not require quashing the discovery because the concerns could be mitigated through a stipulated protective order governing his bank records.
5. Sanctions were not warranted because Chandra did not establish that Kobo's post-judgment discovery was harassing, abusive, unduly burdensome, or obviously irrelevant.

Questions Presented

1. Whether Chandra's pending appeal automatically stayed Kobo's post-judgment discovery.
2. Whether Chandra could object to the discovery as a nonparty after the court added him as a judgment debtor.
3. Whether the post-judgment subpoenas, interrogatories, and debtor's examination were duplicative, overly broad, irrelevant, or disproportionate.
4. Whether Kobo's post-judgment discovery warranted sanctions for harassment or abusive tactics.
5. Whether Chandra's privacy concerns required quashing the discovery or entering a protective order.

Disposition

other