Deborah Frame-Wilson et al. v. Amazon.com, Inc.

District Court, W.D. Washington·Decided March 18, 2026·No. 2:20-cv-00424·Unknown

Opinion

UNITED STATES DISTRICT COURT AT SEATTLE DEBORAH FRAME-WILSON ET AL., CASE NO. 2:20-cv-00424-JHC

Plaintiffs, ORDER v. AMAZON.COM, INC.,

Defendant.

I INTRODUCTION This matter comes before the Court on Defendant Amazon.com, Inc.’s “Surreply Motion to Strike or, in the alternative, for Leave to Respond” (Dkt. # 435) and Plaintiffs’ “Motion to Strike Amazon’s February 6 Filings” (Dkt. # 488). The Court has reviewed the materials filed in connection with the motions, the rest of the record, and the governing law. Being fully advised, the Court GRANTS IN PART and DENIES IN PART both motions. II BACKGROUND In February 2025, Plaintiffs moved to certify a class under Rule 23(b). Dkt. # 266. In connection with their motion, Plaintiffs submitted an Expert Report from Dr. Parag Pathak.1 See Dkt. # 267-1; see also Dkt. # 317-1 (corrected version). In June 2025, Defendant filed its opposition to class certification. Dkt. # 323. It also moved to exclude Dr. Pathak’s expert testimony. See Dkt. # 325. Following various discussions and stipulated motions, the parties and the Court agreed that all contemplated briefing for Plaintiffs’ Motion for Class Certification (Dkt. # 266) and Defendant’s Motion to Exclude Testimony of Parag Pathak, Ph.D. (Dkt. # 325) would be due by November 7, 2025, and January 5, 2026, respectively. See Dkt. ## 350 & 423. The parties complied with these deadlines. See generally Dkt. Five days after Plaintiffs submitted their Reply in Support of Class Certification (Dkt. # 429)—the last scheduled filing for the Motion for Class Certification (Dkt. # 266)—Defendant filed a “Surreply Motion to Strike or, in the alternative, for Leave to Respond” (the Surreply Motion). Dkt. # 435.2 This November 12 Surreply Motion contends that Plaintiffs’ Reply at Dkt. # 429 is improper because it: (1) advances new opinions from Prof. Pathak; (2) redefines the class in a way that “makes it entirely unclear what purchases are Class Products”; (3) offers new opinions from a new expert, Dr. David Sunding; (4) includes a misleading discussion of Prof. Ostrovsky’s deposition testimony; and (5) cites “new factual material, including material that became available after Amazon opposed Plaintiffs’ class certification motion.” Dkt. # 435 at 2–

1 In referring to Dr. Pathak (and the other experts in this case), the parties use “Dr.,” “Prof.,” “Professor,” and “Ph.D.” interchangeably. See generally Dkt. The Court adopts these naming conventions. 2 Defendant later moved for a concurrent expert hearing, which the Court denied on February 26, 2026. See Dkt. ## 448 & 491. 4. And it asks that the Court give Defendant “the opportunity to file a surreply with expert reports by February 6, 2026 . . . or, alternatively, that the new material described at a high level [in this motion] be stricken.” Id. at 2.

The Court did not rule on the Surreply Motion before February 6, 2026. See generally Dkt. Nevertheless, on February 6, 2026, Defendant filed a: (1) “Motion to Exclude Testimony of David Sunding, Ph.D.” (Dkt. ## 472 & 473); (2) “Declaration of Amy J. Mauser in Support of Amazon.com, Inc.’s Motion to Exclude Testimony of David Sunding, Ph.D.” (Dkt. # 474); and (3) “Supplemental Surreply Motion to Strike or, in the alternative, for Leave to Respond” (Dkt. ## 475 & 476). These filings were accompanied by numerous exhibits, including a 3,875-word surreply brief (Dkt. # 476-1), three surrebuttal expert reports (Dkt. ## 476-3–476-5), and hundreds of pages of deposition testimony (Dkt. ## 474-2 & 476-2).3 Plaintiffs now move to strike Defendant’s submissions at Dkt. ## 472–476 (the February 6 Filings). Dkt. # 488. Plaintiffs argue that these documents should be stricken in their totality because they are “unauthorized, untimely, and overlength.” Id. at 15. They also argue that the February 6 Filings are unnecessary and unjustified, as Plaintiffs do not raise any new arguments or evidence on reply. See generally id.; see also Dkt. # 494. III DISCUSSION A. Legal Standards Generally, “[t]he local rules of this District only allow for a motion, response brief from the party opposing the motion, and a reply brief from the moving party.” Clark v. Washington

3 Although not explicitly stated in the Surreply Motion or the documents themselves, Defendant has since clarified that the documents filed at Dkt. ## 472–476 are “proposed” responses and “conditionally submitted,” pending the Court’s resolution of the Surreply Motion. See Dkt. # 493 at 9. State Dep’t of Health, 735 F. Supp. 3d 1334, 1342 n.1 (W.D. Wash. 2024) (citing LCR 7(b)). There are, however, a few exceptions. First, a party may file a surreply—“that is, a second response from a party in

opposition”—without leave of court if they meet the standards of LCR 7(g). Zhai v. Jaddou, 2024 WL 1701973, at *1 n.1 (W.D. Wash. Apr. 19, 2024). Under LCR 7(g), a surreply must be filed within five days of the other party’s reply and cannot exceed 1,050 words. See LCR 7(g)(2)–(3). The contents are also limited to “requests to strike material contained in or attached to a reply brief[.]” LCR 7(g); see also Zhai, 2024 WL 1701973, at *1 n.1 (“A surreply . . . is not permitted, except for a request to strike material from the moving party’s reply brief.”).4 Second, a party may file additional evidence, such as a surrebuttal report, if they obtain permission from the court.5 A court may grant leave to file surreply evidence if: (1) the opposing party raises new evidence or issues in a reply brief or rebuttal report; and (2) the court declines to strike the new materials. See Provenz v. Miller, 102 F.3d 1478, 1483 (9th Cir. 1996) (“Where new evidence is presented in a reply . . . the district court should not consider the new evidence without giving the non-movant an opportunity to respond.”) (citation omitted); see also HDT Bio Corp. v. Emcure Pharms., Ltd., 2022 WL 3018239, at *2 (W.D. Wash. July 29, 2022) (“[W]hen new evidence or issues are raised on reply, courts have discretion to either strike the reply declarations and portions of the reply brief that present new material or consider the new material after affording the nonmoving party an opportunity to respond.”). “Evidence is not 4 Although similar, a surreply motion is distinct from a motion to strike under Federal Rule of Civil Procedure 12(f). See LCR (7)(g)(5). Because Defendant filed a surreply, not a Rule 12(f) motion, the Court limits its analysis to whether the Surreply Motion complies with the procedures set forth in LCR 7(g). 5 See, e.g., PUMA SE v. Brooks Sports, Inc., 2024 WL 2091382, at *4 (W.D. Wash. May 9, 2024) (noting that “Rule 26 does not contemplate surrebuttal reports” but that courts will sometimes still entertain them if the party first seeks permission from the court); Morgan v. Rohr, Inc., 2021 WL 4806472, at *2 (S.D. Cal. 2021) (noting that there is no right to a surreply under the local or federal rules but that a court may still permit a surreply at its discretion). ‘new,’ however, if it is submitted in direct response to evidence or arguments raised in the opposition.” Id. at *3 (collecting cases). And surreply evidence typically must respond directly to the new evidence and issues raised in the reply,6 as evidence that could have been submitted with the opposition or that merely seeks to bolster preexisting evidence is an inappropriate use of a surreply.7 Last, a party can request permission to file a surreply8 brief to present additional substantive arguments.9 On class certification motions, courts may grant leave to file a surreply brief when the plaintiff has substantively modified the class definition in a reply brief10 or when it believes supplemental information is necessary to ensure that it has a complete record.11 As

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Deborah Frame-Wilson et al. v. Amazon.com, Inc., (W.D. Wash. 2026).

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