Financial Technology Partners LP et al. v. Circle Internet Financial Limited

Background

Financial Technology Partners LP and FTP Securities LLC, collectively called FTP, moved to compel Circle Internet Financial Limited to respond to Interrogatory Nos. 13 through 24. The interrogatories sought detailed descriptions of the legal and factual bases for various positions taken by Circle, including the documents supporting those positions.

The dispute arose in an action in which FTP alleges that Circle wrongfully terminated two advisory agreements and failed to pay FTP fees required by those agreements. Discovery was ongoing, and the fact-discovery deadline was July 24, 2026.

Circle objected that FTP had exceeded the 25-interrogatory limit in Federal Rule of Civil Procedure 33(a)(1). FTP argued that it had not exceeded the limit because related subparts should count as one interrogatory and argued that, even if it had exceeded the limit, the court should allow the additional interrogatories.

Legal standards

Rule 33 generally limits a party to 25 written interrogatories, including discrete subparts, unless the court allows more. Additional interrogatories may be allowed when consistent with the discovery rules requiring relevant and proportional discovery and limiting discovery that is unreasonably cumulative, duplicative, or unnecessarily burdensome.

Rule 33 also permits “contention interrogatories,” which ask an opposing party to identify the facts, evidence, and legal applications supporting its claims or defenses. A party may ask the court to compel answers when the other party refuses to respond.

Analysis

The court agreed with FTP that Interrogatory Nos. 7 and 9 through 24 were not improperly combined questions. The court found that their subparts were logically or factually connected and therefore constituted single interrogatories. For example, several interrogatories addressed whether Circle had grounds under particular agreements to terminate them. The court also treated Interrogatory No. 18, concerning a contractual carveout, and Interrogatory No. 20, concerning a single capital raise, as single interrogatories despite their multiple conditions or details.

The court declined to recount all the interrogatories. Even assuming FTP had exceeded the 25-interrogatory limit, the court found that FTP had made a particularized showing that the likely benefit of the additional interrogatories outweighed the burden on Circle and that the requests were consistent with the discovery rules. The court also found that FTP had not forfeited its right to receive answers merely because its motion focused on the numerical-limit issue.

The court stated that some of Circle’s other objections appeared unsupported. In particular, Circle’s objection to providing the legal bases for the contentions was not well founded because Rule 33 expressly permits questions about the application of law to facts. But the court did not decide all of Circle’s remaining objections or immediately compel answers.

Disposition

The court granted in part and denied in part FTP’s letter motion. It directed the parties to meet and confer about any remaining objections Circle wished to assert as grounds for refusing to respond. If they could not reach an agreement, the parties had to file a joint letter of no more than eight pages stating their respective positions by July 24, 2026. The opinion does not state that the court immediately ordered Circle to provide the requested responses.