Metro Light and Power LLC v. Furnlite, Inc.

Background

Metro Light and Power LLC sued Furnlite, Inc. and Group Dekko, Inc. The opinion states that Metro’s amended complaint alleges copyright infringement involving Dekko’s FC-1200 Series faceplate, along with allegations that Dekko copied images from Metro’s website, made and sold infringing faceplates, and misappropriated Metro’s goodwill.

During discovery, Metro served document subpoenas on two nonparties: icSourcing & Logistics, Inc. and Kevin Cramp. The subpoenas sought documents and communications concerning faceplates and related products, including product lines identified as FC-760, FC-770, FC-780, FC-73X, FC-74X, FC-1200, FC-1600, and FC-22200. The requests covered periods beginning in 2019 and included information about rectangular, square, round, and oval faceplates.

Furnlite and Group Dekko, referred to collectively in their filing as “Dekko,” moved to quash the subpoenas. They argued that the requests were not relevant or material to Metro’s claims and imposed an undue burden on the nonparties. They asserted that Metro’s case concerned only the FC-1200 Series faceplate. Metro offered to narrow the subpoenas after the parties met and conferred, but Dekko maintained that the revised requests remained too broad.

Legal standard and ruling

The filing relied on Federal Rule of Civil Procedure 45, which permits a court to quash or modify a subpoena that subjects a person to undue burden. It also stated that subpoena requests must satisfy the relevance requirement governing discovery and that courts should protect nonparties from significant expense. The opinion states that a party generally lacks standing to challenge a subpoena issued to a nonparty on relevance or undue-burden grounds. It then states: “So the motion to quash is DENIED.”

The court denied the motion to quash and directed the clerk to terminate motions at ECF Nos. 71 and 72. The opinion is a discovery ruling; it does not decide whether Metro’s copyright or other claims are valid.