Automotive Body Parts Association v. Ford Global Technologies, 4:13cv0070 (9/16/14)
Judge: Amos Mazzant
Holding: Motion to Quash Deposition and Document Subpoenas Denied
The Court begins by noting that this is a "unique" patent case in that the plaintiff requests that the court declare that six patents owned by defendant Ford are invalid and/or unenforceable under the doctrines of functionality and patent exhaustion. In order to satisfy its burden to demonstrate that at least one of its members would have standing to sue in order to establish associational declaratory judgment standing, plaintiff identified the two co-owners and officers of one of its members.
This order resolved a motion to quash filed by the plaintiff in response to deposition and document subpoenas directed to these individuals which it contended were overbroad.
The court analyzed the potentially soon–to-be–obsolete definition of relevance in FRCP 26, including the broadened scope available of "any matter relevant to the subject matter involved in the action" upon a showing of good cause, as well as the teachings of Local Rule CV–26(d).
The Court began by denying the motion to quash the document subpoenas, noting that Ford was not currently pursuing its document production against the individuals. It similarly denied the motion to quash the second noticed deposition as premature at this time. With respect to the first noticed deposition, however, the court found that the deposition was relevant and that compliance with the subpoena would not be unduly burdensome, unreasonable, or oppressive. The Court concluded by instructing the parties to work together in good faith to schedule the depositions of these individuals, and invited the parties to contact it to schedule a telephone conference if they need assistance.