Digital Forensics Corporation, LLC v. King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc. (Appeal from Jefferson Circuit Court: CV-22-900222).

CourtSupreme Court of Alabama
DecidedJanuary 10, 2025
DocketSC-2024-0031
StatusPublished

This text of Digital Forensics Corporation, LLC v. King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc. (Appeal from Jefferson Circuit Court: CV-22-900222). (Digital Forensics Corporation, LLC v. King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc. (Appeal from Jefferson Circuit Court: CV-22-900222).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Digital Forensics Corporation, LLC v. King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc. (Appeal from Jefferson Circuit Court: CV-22-900222)., (Ala. 2025).

Opinion

Rel: January 10, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2024-2025

_________________________

SC-2024-0031 _________________________

Digital Forensics Corporation, LLC

v.

King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc.

Appeal from Jefferson Circuit Court (CV-22-900222)

WISE, Justice.

Digital Forensics Corporation, LLC ("DFC"), appeals from the

Jefferson Circuit Court's order denying its motion to compel arbitration.

Procedural History SC-2024-0031

On January 21, 2022, King Machine, Inc., and Hartford Fire

Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King

Machine, Inc. ("the plaintiffs"), sued DFC in the Jefferson Circuit Court.

In their complaint, the plaintiffs alleged that they had retained DFC to

perform electronic-discovery services related to a discovery order entered

in litigation in the Etowah Circuit Court. The factual allegations in the

complaint included the following:

"7. In the Fall of 2018, Plaintiffs began to discuss with Digital Forensics Corporation (hereinafter 'Defendant') the possibility of Defendant performing electronic discovery and digital forensics services for the Plaintiffs. In conducting an investigation as to the capabilities of the Defendant, the Plaintiffs examined the Defendant's website, where the Defendant holds itself out as a computer forensics and e- discovery expert. The website includes such statements and representations as: 'Where discovery meets evidence;' 'Quick turnaround times for data acquisition and extraction of cell phones, hard drives, and/or cloud-based accounts.'

"8. The Defendant's website relating to litigation support states: 'Digital Forensics Corporation offers over of [sic] ten (10) years of experience in identifying, collecting and producing electronically stored information (ESI) in response to a legal request for production.' The website states that Digital Forensics Corporation is a qualified expert to perform court ordered forensic imaging, the preservation of data, cloud account extraction and the segregation of data. Potential customers are instructed that they will be able to: 'Go into court with compelling digital evidence.' The website also states: 'Customized acquisition process adheres to court ordered specifications.' It states that the Defendant is able to 2 SC-2024-0031

provide: 'Consultation to identify potentially discoverable information.' It states: 'Extracted data provided in an easily sortable searchable format.'

"9. It also states: 'Digital Forensics Corporation specializes in identification and preservation of electronically stored information for use in both civil and criminal legal matters. E-discovery and ESI includes, but it is not limited to: Emails, documents, presentations, data bases, audio and video files, social media, websites and text messages.'

"10. It also states: 'Digital Forensics Corporation leads the industry due to a hands on approach using information technology using litigation support experience. Our combination of focused business and IT experience allows our Expert Engineers to provide cost-effective e-discovery and ESI solutions.'

"11. These are just some of the representations made by the Defendant that 'sets us [the Defendant] apart.' The website also describes the manner in which the Defendant presents data to customers: 'DFC provides extracted evidence in a format that can be easily searched and sorted, so attorneys can produce specific reports for presentations in court. Data can be provided on an external drive or via secured cloud-based portal.' This was a false statement. These statements were misrepresentations of Defendant's capabilities, including its capabilities in regard to the electronic discovery services.

"12. The misrepresentations were of material facts. Plaintiffs reasonably relied upon the misrepresentations in entering into the agreement with Defendant.

"13. Further conversations with the representatives of the Defendant included the same, similar and other representations that DFC was capable of delivering timely and efficient ESI e-discovery results. These representations 3 SC-2024-0031

were also untrue. Therefore, the representations concerning the capabilities of the Defendant in regard to e-discovery and the production of documents and information through the e- discovery process that were made by Defendant's representatives were false and fraudulent.

"14. The Defendant's representatives never disclosed that they were incapable of performing for Plaintiffs as represented.

"15. The representations made by the Defendant were reasonably relied upon by Plaintiffs in engaging in further discussions with the Defendant regarding e-discovery services and ultimately retaining the Defendant as a vendor to assist the Plaintiffs in conducting electronic discovery in a case pending in the Circuit Court of Etowah County, Alabama styled R.C. Mold & Machine, Inc. and Quality Mold, Inc. v. Sean Sommers, Micron Precision, LLC and King Machine Americas, LLC (Civil Action No.: CV-17-900606) (hereinafter 'the R.C. Mold lawsuit').

"16. DFC also represents on its website that its employees include certified forensic computer examiners and repeatedly holds itself out as an expert in electronic discovery and capable of performing the work needed and contracted for Plaintiffs. These representations made by DFC on its website were reasonably relied upon by Plaintiffs. These representations also proved to be false.

"17. In addition, numerous DFC employees and representatives represented to Plaintiffs' attorneys that they could accomplish the mandates of the E-Discovery Order. These employees included, but were not necessarily limited to Robert Bixby (Agent 1219), Brent G. Walters (Analyst), Kenneth Probola (Customer Service Specialist), Mark Daniel (Sales Manager), and Chad Smith (Customer Service Manager). The representations made on DFC's website and by DFC's representatives were representations of material 4 SC-2024-0031

fact that were relied upon by Plaintiffs in entering into an agreement with DFC and beginning work on e-discovery issues with DFC's assistance. The representations made verbally and in correspondence between Plaintiffs and DFC representatives and employees led Plaintiffs to retain DFC for e-discovery needs. Therefore, on December 12, 2018, a wire transfer in the amount of $9,992.00 was sent to DFC as an initial retainer."

The plaintiffs went on to allege:

"42. Ultimately, Plaintiffs continued to work with DFC, but DFC was not able to put the data and documents into a format that could be transferred, used and searched by opposing counsel as required by the ESI Discovery Order and the instructions contained therein, which, as noted, were sent to DFC on November 28, 2018, and were also attached to the questionnaire sent to DFC in January 2019. … They were also sent to Mr. Daniel in September 2019.

"43. While Plaintiffs were working with DFC to resolve the e-discovery issues and after DFC had received the initial retainer of $9,992.00, DFC continued to demand retainers to go forward with any work.

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Digital Forensics Corporation, LLC v. King Machine, Inc., and Hartford Fire Insurance Company, as subrogee of Micron Precision, LLC, d/b/a King Machine, Inc. (Appeal from Jefferson Circuit Court: CV-22-900222)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/digital-forensics-corporation-llc-v-king-machine-inc-and-hartford-fire-ala-2025.