Amazon.com, Inc. v. Personal Web Technologies, LLC

Background

Amazon.com, Inc., Amazon Web Services, Inc., and Twitch Interactive, Inc., collectively called “Amazon” in the order, pursued post-judgment discovery from third-party investors in PersonalWeb Technologies, LLC. Amazon sought information about the investors’ relationship with PersonalWeb and financial information in connection with efforts to trace PersonalWeb’s assets and enforce a judgment. The discovery requests were made through subpoenas for document production.

The third parties opposed Amazon’s motion to compel. They argued that a Los Angeles County Superior Court receivership action was the first and only court with jurisdiction over PersonalWeb, its secured creditors, its assets, and the relationships among those parties and assets. They relied on the rule that the court first assuming jurisdiction over property may keep that jurisdiction to the exclusion of another court.

Court’s analysis

The court explained that the property-jurisdiction rule applies when both proceedings are actions involving property. The federal proceeding in which Amazon issued the subpoenas was instead an action against persons, rather than an action against property. The third parties did not dispute that distinction.

The court relied on precedent stating that state courts cannot bar the prosecution of actions against persons in federal court. It therefore found the property-jurisdiction authority cited by the third parties inapplicable. The court also rejected the third parties’ additional arguments based on respect for the state court and their suggestion that Amazon’s discovery efforts interfered with the receivership proceeding.

The court stated that post-judgment discovery is broad and generally includes matters arguably related to tracing a debtor’s assets and enforcing a judgment. It also cited Federal Rule of Civil Procedure 69(a)(2), which allows a judgment creditor to obtain discovery from any person under the federal rules or the procedure of the state where the court is located.

Disposition

Judge Susan Van Keulen granted Amazon’s motion to compel production of documents under the subpoenas identified in the parties’ joint submission. Each third party, as defined in the subpoenas, must provide responses and produce non-privileged, nonprotected responsive documents within that party’s possession, custody, or control within 14 days of the order. The court resolved the matter without oral argument under Civil Local Rule 7-1(b).