Mujae Group, Inc. v. Spotify USA Inc.
- Alvin Hellerstein
- 1:20-cv-06719
- U.S. District Court · Southern District of New York
- 3
In Mujae Group v. Spotify USA, Judge Hellerstein denied two discovery requests without prejudice, involving confidential information and third-party privacy.
Mujae Group, Inc., Spotify USA Inc., Nadeem Mughal, and third-party employees whose personal cellphone or social-media data was sought.
What happened
Mujae Group, Inc. and Spotify USA Inc. disputed proposed rules for protecting confidential information and handling electronically stored information. Mujae sought access for its sole employee and corporate representative, Nadeem Mughal, to Spotify’s attorneys’-eyes-only information, and sought personal cellphone and social-media data belonging to third-party employees.
The court found that giving Mughal unrestricted access could risk disclosure of Spotify’s trade secrets because he could make competitive decisions. It also found that Mujae had not identified specific people or provided narrowly tailored reasons for seeking third parties’ private data.
Judge Alvin K. Hellerstein denied both requests without prejudice, allowing Mujae to renew them under specified procedures or after identifying specific custodians. The parties were ordered to revise their proposed protective and electronically stored information orders to match the rulings.
The detailed version
- Mujae Group, Inc. v. Spotify USA Inc. · No. 1:20-cv-06719
- Alvin Hellerstein
- June 30, 2021
Background
The parties submitted letters describing disputes about a proposed protective order and a proposed electronically stored information (ESI) order. The first dispute concerned whether Nadeem Mughal, Mujae’s sole employee and sole corporate representative, could view Spotify’s “Attorneys’ Eyes Only” (AEO) information. The second concerned whether Mujae could obtain third-party employees’ personal cellphone and personal social-media data.
Federal Rule of Civil Procedure 26 generally permits discovery of relevant, nonprivileged information that is proportional to the needs of the case. It also allows a court, for good cause, to protect a party or person from harm or undue burden. The court explained that AEO restrictions are commonly used when discovery may reveal trade secrets and that confidential information may be withheld from a client and reviewed only by the client’s attorneys.
Rulings
The court denied Mujae’s request to give Mughal access to Spotify’s AEO information, without prejudice to renewal under the procedures in the proposed protective order after Mujae’s counsel inspected the information. The court reasoned that Mughal’s unrestricted access could expose Spotify’s trade secrets to someone capable of making competitive decisions. The court also noted that Mujae had retained sophisticated counsel trained in law and engineering who could review and analyze the information.
The court denied Mujae’s request for access to third-party employees’ personal cellphone and social-media data, without prejudice to renewal after Mujae identified specific custodians. The court emphasized the privacy interests of innocent third parties and found that Mujae had not identified specific individuals or supplied narrowly tailored reasons supporting blanket access to private information.
The court directed the parties to submit proposed protective and ESI orders consistent with these rulings. It also directed the Clerk of Court to terminate the open motion to enter an opposed proposed order because that motion had been withdrawn.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.