Vinci Brands LLC v. Coach Services, Inc.

Background

ACS Group Acquisitions LLC filed a letter motion seeking to compel nonparty JPMorgan Chase to comply with a subpoena served around August 9, 2024. The subpoena sought documents concerning a potential acquisition of Vinci Brands LLC and documents related to Case-Mate’s license agreement with Kate Spade, among other materials. Chase had not responded. Case-Mate filed a letter opposing the motion.

Standing and Notice

The court explained that a party generally may not challenge a subpoena directed to a nonparty unless it claims a privilege or has a privacy or proprietary interest in the requested documents. The court noted that financial information may create a privacy interest. Although Case-Mate ordinarily would not have standing—the legal ability to challenge the subpoena—the court said it was not clear that Case-Mate lacked a privacy or other proprietary interest in the documents. The court also said ACS’s motion did not clearly show that ACS had notified Chase about the motion to compel.

Order

Judge Figueredo did not grant or deny ACS’s motion to compel in this order. She directed ACS to submit a letter by February 11, 2025, confirming that it had served Chase with notice of the motion and a copy of the order. Chase was given until February 28, 2025, to oppose the motion or request an extension. Case-Mate was directed to file a letter by February 21, 2025, explaining the basis for any privilege, privacy, or proprietary interest that could give it standing to challenge the subpoena.

Effect of the Order

The order required additional notice and briefing before the court decided whether Chase should be compelled to comply with the subpoena. The text provided does not state the ultimate result of the motion to compel.