Crosby v. Amazon.com Inc

District Court, W.D. Washington·Decided December 7, 2023·No. 2:21-cv-01083·Unknown

Opinion

THE HONORABLE JOHN C. COUGHENOUR 1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9 CRAIG CROSBY and CHRISTOPHER CASE NO. C21-1083-JCC JOHNSON, on behalf of themselves and all 10 others similarly situated, ORDER 11 Plaintiffs, 12 v. 13 AMAZON.COM, INC., 14 Defendant. 15

16 This matter comes before the Court on Plaintiffs’ motion to compel and for sanctions 17 (Dkt. No. 96) along with the parties’ motions to seal (Dkt. Nos. 99, 109). Having duly considered 18 the record and the briefing, the Court GRANTS in part and DENIES in part each motion for the 19 reasons described below. 20 A. Motion to Compel 21 The Court has issued four discovery orders preceding the instant motion. (See Dkt. Nos. 22 49, 58, 74, 90.) Pursuant to those orders, Defendant must produce discovery responsive to 23 Plaintiffs’ jurisdictional requests, at least as they relate to Amazon Warehouse Deals’ (“AWD”) 24 products containing 18650 rechargeable batteries, regardless of whether the battery type is stated 25 within AWD’s advertising (i.e., “title 18650 batteries” and “non-title 18650 batteries”), so long 26 as the advertising includes potentially dubious assertions regarding the batteries’ energy 1 capacity. (See id.) In again moving to compel, Plaintiffs repeat their assertion that Defendant’s 2 search for sales of such products during the relevant time period1 was deficient. (See Dkt. No. 96 3 at 10.) Specifically, Plaintiffs’ take issue with two aspects of Defendant’s search of its product 4 catalogue (as described below), and additionally complain that Defendant’s 30(b)(6) deponent 5 was not prepared to respond to questions during his deposition. (Dkt. No. 96 at 12–14.). 6 As to the search, Defendant limited it to those products referencing “18650” as a 7 searchable product attribute (what it describes as a search of its catalogue’s “first-class 8 attributes”). (Dkt. No. 115 at 9.) Nor did Defendant search its accompanying image catalogue for 9 dubious energy claims, (see Dkt. No. 96 at 8), despite prior direction to do so. (See Dkt. No. 90 10 at 3.) At least with respect to the catalogue data search, Defendant asserts the method it 11 employed, i.e., first limiting its search to products with an “18650” reference, was the most 12 logical way. (Dkt. No. 115 at 9.) This is because Defendant has no mechanism to directly 13 identify non-title 18650 batteries, or products containing those batteries, within its product 14 catalogue. (Id.) 15 1. 18650 Battery Search 16 Again, the Court ordered Defendant to provide Plaintiffs with jurisdictional discovery 17 relevant to AWD’s sales of both title and non-title 18650 rechargeable batteries. (Dkt. No. 90 at 18 3.) The Court did not limit this order to sales of products with an “18650” stored as a value 19 somewhere in AWD’s catalogue. While Defendant’s strategy correctly identifies those products, 20 it does not do enough to capture the sales of all non-title 18650 batteries. Specifically, to the 21 extent that there is “no first-class attribute that identifies through a binary Boolean selection— 22 Yes/No or True/False—a product as containing an 18650 battery,” (Dkt. No. 115 at 9), the Court 23 does not view this as an excuse to avoid providing Plaintiffs with the discovery needed to 24

25 1 This is presently limited to those products sold from May 4 through the complaint date of 26 August 13, 2021. 1 establish this Court’s jurisdiction over their claims. 2 As a result, Defendant must comply with its discovery obligation through one of two 3 means: First, Defendant may provide Plaintiffs with a detailed description of any first-class 4 attribute that could hold information which indicates a product contains non-title 18650 5 batteries.2 Plaintiffs, once equipped with a description of these attributes, would then need to 6 provide search terms to Defendant, and Defendant’s custodians must then perform a search using 7 those terms.3 Second, if this is overly burdensome, Defendant shall provide Plaintiffs with raw 8 catalogue data of all AWD sales during the relevant time period. See Fed. R. Civ. P. 9 34(b)(2)(E)(i). It would then be Plaintiffs’ obligation to concoct a methodology to search for 10 potentially responsive products within this data, in its effort to support the jurisdictional 11 requirement(s) in this case. 12 2. Energy Capacity Image Searching 13 As the Court has previously ordered, Defendant must search for advertised energy 14 capacity in any of the text fields or accompanying photos of products sold by AWD during the 15 relevant period, if they contain title and/or non-title 18650 batteries. (See Dkt. No 58 at 3.) Yet, 16 Defendant has not done so. (See Dkt. No. 101-1 at 94.) Again, Defendant has two options. First, 17 after properly using Plaintiffs’ search terms as directed above, Defendant must review all images 18 for those products and, to the extent they contain a claimed energy capacity, provide that image 19 to Plaintiffs. Second, if this is overly burdensome, Defendant shall provide Plaintiffs with all 20 images of products sold by AWD during the relevant time period. See Fed. R. Civ. P. 21 22 2 This directive should be read broadly, but reasonably. For example, Defendant should be expected to provide information for an attribute relating to the manufacturer (e.g., where the 23 value “Dyson” might be stored for a Dyson vacuum). However, Defendant is not expected to provide information relating to a product’s color, for example. At a minimum this must include 24 all 23 attributes noted by Plaintiffs. (See Dkt. No. 100 at 11.) 25 3 Similarly, this should also be reasonable as to not burden the Defendant. Plaintiffs must explain to Defendant why they think this search term may reasonably result in a successful search for 26 products containing non-title 18650 batteries. 1 34(b)(2)(E)(i). It would then be Plaintiffs’ obligation to concoct a methodology to search for 2 potentially responsive products within these images. 3 3. 30(b)(6) Representative 4 Plaintiffs argue Defendant’s corporate representative was unprepared for a deposition 5 relating to two topics in Plaintiffs’ jurisdictional discovery request. (See Dkt. No. 96 at 12.) 6 However, in the Court’s view, the issue is relevance—not preparedness. Plaintiffs, in moving to 7 compel, clearly believe that a Rule 30(b)(6) deponent is required to answer questions regarding 8 Amazon’s corporate structure and the operations of its branches other than AWD. (Id. at 13.) 9 And they take issue with the fact that the designated representative, Ashkay Atwe, was unable to 10 do so. (Id.)4 But the Court fails to see how Amazon’s overall organizational structure and/or the 11 operations of non-AWD branches is relevant to determining how much revenue AWD generates 12 from the sale of 18650 batteries with dubious energy claims. 13 4. Sanctions 14 As a sanction for Defendant’s alleged failure to comply with this Court’s prior orders, 15 Plaintiffs ask the Court to extend the relevant time period subject to jurisdictional discovery. 16 (Dkt. No. 96 at 14.) Indeed, sanctions are appropriate when a party fails to obey a discovery 17 order. See Fed. R. Civ. P. 37(b)(2). But the situation here is more nuanced. Defendant did not 18 refuse to search for non-title 18650 products; rather, it would seem its data systems do not 19 provide a ready way to do so. (See Dkt. No. 111 at 7–9.) And while Defendant failed to work 20 collaboratively with Plaintiffs to fashion a work-around, this, alone, is not sufficient to warrant 21 sanctions.

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