Garner v. Amazon.com Inc

District Court, W.D. Washington·Decided October 3, 2022·No. 2:21-cv-00750·Unknown

Opinion

4 UNITED STATES DISTRICT COURT 5 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 6 7 KAELI GARNER, et al., Cause No. C21-0750RSL 8 Plaintiffs, ORDER GRANTING IN 9 v. PART DEFENDANTS’ 10 MOTION TO COMPEL AMAZON.CO, INC., et al., 11 Defendants. 12 13 This matter comes before the Court on “Defendants’ Motion to Compel.” Dkt. # 106. 14 15 Having reviewed the memoranda, declarations, and exhibits submitted by the parties, the Court 16 finds as follows: 17 A. Interrogatories Seeking Identification of Plaintiffs’ Recordings and the Subset of 18 Recordings at Issue in this Case 19 20 Defendants seek to compel plaintiffs to identify audio recordings that contain their voice 21 and, in particular, the audio recordings are at issue in this case. Interrogatory 5 requests that each 22 plaintiff identify by date, time, and content each Alexa audio recording associated with their 23 23 Amazon account that contains their voice. Interrogatories 6, 7, and 8 (and in some cases 25 Interrogatory 9) are designed to identify those recordings that each plaintiff contends were 26 private and confidential conversations that were not directed to Alexa. Plaintiffs object on the 27 28 1 grounds that Amazon has refused to produce audio recordings for all but five named plaintiffs 2 and that the parties were in the midst of negotiating a production, review, and transcript 3 annotation process when Amazon precipitously filed this motion to compel. 4 5 The Court declines to evaluate the merits of Amazon’s objections to plaintiffs’ discovery 6 requests in the context of this motion to compel. Plaintiffs may not refuse to produce responsive 7 documents or information simply because they believe that Amazon has failed to meet its 8 9 discovery obligations. The only relevant issue is whether Amazon’s refusal to make the audio 10 recordings and transcripts available has prevented plaintiffs from responding to Amazon’s 11 discovery requests. 12 13 To a certain extent, that appears to be the case. At various points, Amazon argues that 14 plaintiffs and their counsel have always had access to their audio recordings and transcripts 15 through an on-line Amazon portal or the Alexa app (Dkt. # 106 at 11) and, contrarily, that there 16 17 is reason to suspect that plaintiffs and their counsel are not authorized to access the information 18 at all (Dkt. # 110 at 6). The difference appears to involve the way in which the Alexa account is 19 held. If a named plaintiff is the account holder and no other plaintiff is seeking access to the 20 21 account (as is the case for five of the twenty-one named plaintiffs)1, the account holder not only 22 has password access to the digital files, but Amazon has been willing to assume that counsel is 23 authorized to obtain the information requested and has produced the audio recordings and 23 25

26 1 While this motion was pending, eleven of the named plaintiffs voluntarily dismissed their claims against defendants. The numbers set forth in this Order reflect the pre-dismissal status of the 27 claims. 28 1 transcripts for those five plaintiffs. With regards to the twelve plaintiffs who live with another 2 plaintiff, however, Amazon has refused to provide the audio recordings and transcripts for the 3 account even though the account holder has requested them through properly-served discovery 4 5 requests, apparently on the ground that a non-account holder plaintiff joined in the request. 6 While this position is baffling, it is undisputed that the account holders have access to the 7 information through the on-line Amazon portal and/or Alexa app and may share that access with 8 9 their non-account holder spouses. Plaintiffs make no effort to show that this form of access is 10 insufficient to allow the co-habitating plaintiffs to respond to the interrogatories seeking 11 identification of each plaintiff’s recordings and the subset of recordings at issue in this case. 12 13 Thus, with regards to at least seventeen named plaintiffs, there is no impediment to their 14 providing full and complete responses to the interrogatories. 15 There is a third group of plaintiffs who apparently cannot access the information 16 17 necessary to respond, however. With regards to plaintiffs Kaeli Garner, Ricky Babani, and 18 Caron Watkins,2 their claims are based on the allegation that they were recorded by Alexa 19 devices owned by non-parties. Although there is some indication that the account holders have 20 21 authorized Amazon to produce the audio recordings and associated transcripts in discovery, 22 there is no evidence that the account holders have turned over their passwords or other access 23 codes to plaintiffs such that they could obtain the records themselves. Amazon continues to 23 25 26 2 The Court is aware that the number of named plaintiffs discussed in this paragraph totals 27 twenty but has been unable to ascertain into which category the last plaintiff falls. 28 1 refuse to provide audio recordings or transcripts related to accounts of non-parties. These three 2 plaintiffs will not be compelled to provide documents or information they do not have and to 3 which they have no right of access. 4 5 Plaintiffs argue that it would be unduly burdensome to require them to review all of their 6 audio recordings and/or to annotate all of their Alexa transcripts and that such a requirement 7 would not be proportional to the needs of the case. These assertions are wholly unsupported. 8 9 There can be no doubt that the information sought is essential to plaintiffs’ claims and/or 10 Amazon’s defenses. Each plaintiff’s familiarity with and use of Alexa will shed light on the 11 adequacy of Amazon’s disclosures, the user’s awareness that recordings were made, stored, and 12 13 reviewed, and the user’s control over the recordings. Each plaintiff will ultimately have to show 14 that communications were improperly recorded: requiring them to identify the recordings that 15 form the basis of their wiretap claims is therefore entirely proportional to the needs of the case. 16 17 Nor is there any indication that the account holder plaintiffs or their non-account holder spouses 18 have attempted to determine the number or length of the recordings or transcripts at issue. In the 19 absence of such basic information (or some other metric from which one could make a 20 21 reasonable estimate of the number of hours it would take to review, annotate, and produce the 22 requested materials), a claim of undue burden is unpersuasive given the importance of the 23 information. 23 25 Finally, plaintiffs argue that the motion to compel responses to these interrogatories is 26 premature because the parties had not reached an impasse. That does not appear to have been the 27 28 1 case. Defendants requested that plaintiffs identify any recording of their voice as well as the 2 subset of those recordings that form the basis for their claims. As part of the meet and confer 3 process, defendants identified sources for the audio recordings and related transcripts and 4 5 proposed that plaintiffs simply annotate the transcripts rather than typing out responses to 6 individual interrogatories. Plaintiffs did not accept that proposal, instead insisting that Amazon 7 produce the recordings and transcripts for review, at which point plaintiffs would be willing to 8 9 discuss the extent to which they would provide responses. Having rejected defendants’ proposal 10 and steadfastly refused to provide any responsive information, defendants appropriately sought 11 the Court’s intervention. 12 13 B. Verified Amended Responses Prior to Depositions 14 The parties agree that plaintiffs shall provide verified amended responses from each 15 plaintiff no later than three weeks before their scheduled deposition. It is so ordered. 16 17 C.

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Garner v. Amazon.com Inc, (W.D. Wash. 2022).

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