HIT NOTION LLC v. SANDERS COLLECTION INCORPORATED

CourtDistrict Court, E.D. Michigan
DecidedFebruary 12, 2026
Docket2:24-cv-10937
StatusUnknown

This text of HIT NOTION LLC v. SANDERS COLLECTION INCORPORATED (HIT NOTION LLC v. SANDERS COLLECTION INCORPORATED) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HIT NOTION LLC v. SANDERS COLLECTION INCORPORATED, (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

HIT NOTION LLC,

Plaintiff, Case No. 24-cv-10937 v. Honorable Robert J. White SANDERS COLLECTION INCORPORATED,

Defendant.

ORDER DENYING DEFENDANT’S MOTION TO QUASH AND FOR A PROTECTIVE ORDER

This case involves Plaintiff’s claims for copyright and willful patent infringement, as well as the parties’ competing claims for breach of contract. (ECF Nos. 1, 14). Before the Court is Defendant’s motion to quash a subpoena to Amazon.com, Inc. (Amazon) and for a protective order. (ECF No. 31). The Parties fully briefed the motion and the Court will decide it without oral argument pursuant to Local Rule 7.1(f)(2). For the following reasons, the Court denies the motion. I. Background Plaintiff filed this action on April 10, 2024. (ECF No. 1). The case essentially involves (1) Plaintiff’s copyright(s) and design patents with respect to a particular pillow product; (2) Defendant’s alleged infringement of the copyright(s) and patents via the advertising and sale of similar products; and (3) the parties’ competing claims that the other breached a settlement agreement that previously resolved a similar

infringement dispute regarding the same or similar products. (ECF Nos. 1, 14). Plaintiff subpoenaed Amazon on June 6, 2025, requesting production, subject to the protective order in this case (ECF No. 23), of the following:

1. Documents sufficient to show all units sold of each Listing from February 17, 2020 to the present.

2. Documents sufficient to show the purchase price of each Listed Product for all sales between February 17, 2020 to the present.

3. Documents sufficient to show any fees, discounts, or proceeds associated with all sales of any Listed Product between February 17, 2020 to the present.

4. Documents sufficient to show any keyword advertising efforts by Sanders (or its affiliates including but not limited to Nestl, Clara Clark, and TheComfortZone) associated with any Listing.

5. Documents sufficient to show any keyword advertising efforts by Sanders (or its affiliates including but not limited to Nestl, Clara Clark, and TheComfortZone) associated with the term, “husband pillow.”

6. Documents and information pertaining to any and all advertising associated with any Listing which may be found in Amazon [records].

(ECF No. 31-2, PageID.316-17). The subpoena defined “Listing” and “Listed Product” as including over 100 different specific product/catalog identification codes for each of two different Amazon sellers affiliated with Defendant. (ECF No. 31-2, PageID.314-15). On June 30, 2025, Defendant moved (1) to quash the Amazon subpoena and (2) for a protective order “precluding Plaintiff from making similar requests on

[Amazon] or other non-party e-commerce platforms.” (ECF No. 31, PageID.271). Defendant argues that (1) it has standing to quash the Amazon subpoena based on a personal interest in the records sought; (2) the subpoena should be quashed because

it seeks sales data that Defendant already produced through discovery; and (3) the subpoena should be quashed because none of the listings identified therein “offer[] for sale an accused product,” rendering the requested sales and advertising information completely irrelevant to the parties’ dispute and the currently-pled

claims. (ECF No. 31, PageID.2380-88). In response, Plaintiff first counters that it subpoenaed the records from Amazon based on its owner’s well-founded belief that Defendant’s self-reported

sales are inaccurate or incomplete. (ECF No. 32, PageID.411-12). Plaintiff argues that “the only way forward is to get the information from Amazon” because of Defendant’s apparent inability or reluctance to independently produce its full and accurate sales records. (ECF No. 32, PageID.412-14). Plaintiff also argues that the

information sought from Amazon is relevant and not overbroad. (ECF No. 32, PageID.414-20). Lastly, Plaintiff argues that Defendant’s cited cases to establish standing are distinguishable and fail to do so here. (ECF No. 32, PageID.42-21). In reply, Defendant argues that (1) it already produced sales data in response to Plaintiff’s demands in this case, (2) Plaintiff’s position that Defendant’s provided

data is inaccurate or incomplete is unfounded and wholly speculative, and (3) all the information sought relates to non-infringing products and is irrelevant here. (ECF No. 468).

II. Legal Standards “The decision to quash a subpoena is . . . within the sound discretion of the district court.” Thomas v. City of Cleveland, 57 F. App’x 652, 654 (6th Cir. 2003) (unpublished). “A motion to quash or modify a subpoena is governed by Fed. R.

Civ. P. 45(d)(3).” Malibu Media, LLC v. Doe, No. 15-10307, 2015 U.S. Dist. LEXIS 53784, at *2-7 (E.D. Mich. Apr. 24, 2015). “First, a court ‘must quash or modify a subpoena that: (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits specified in Rule 45(c); (iii) requires

disclosure of privileged or other protected matter, if no exception or waiver applies; or (iv) subjects a person to undue burden.’ Fed. R. Civ. P. 45(d)(3)(A).” Id. “Further, a court ‘may, on motion, quash or modify the subpoena if it requires: (i) disclosing

a trade secret or other confidential research, development, or commercial information; or (ii) disclosing an unretained expert’s opinion or information that does not describe specific occurrences in dispute and results from the expert’s study that was not requested by a party.’ Fed. R. Civ. P. 45(d)(3)(B).” Id. “The party seeking to quash the subpoena bears the burden of demonstrating that the requirements of Rule 45 are satisfied.” Id. And “a party does not have

standing to quash a subpoena directed to a nonparty unless the party claims a privilege, proprietary interest, or personal interest in the information sought by the subpoena. The party seeking to quash a subpoena bears a heavy burden of proof.”

Id. Further, the scope of discovery for a subpoena under Fed. R. Civ. P. 45 is the same as under Fed. R. Civ. P. 26(b)(1). State Farm Mut. Auto. Ins. Co. v. Elite Health Ctrs., Inc., 364 F. Supp. 3d 758, 767 (E.D. Mich. 2018). Under Rule 26(b)(1),

“[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense,” except that the Court must consider proportionality factors, including “the importance of the issues at stake in the action, the amount in

controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” See also Hendricks v. Total Quality Logistics, LLC, 275 F.R.D. 251, 253-56 (S.D. Oh. May 6,

2011) (granting the plaintiffs’ motion to quash third-party subpoenas seeking the plaintiffs’ employment and scholastic records because the subpoenas sought largely irrelevant information and were otherwise overly broad). When “an objection to the relevance of the sought discovery is raised, the party seeking discovery must demonstrate that the requests are relevant to the claims

or defenses in the pending action.” Gazvoda v. Sec’y of Homeland Sec., No. 15- 14099, 2017 U.S. Dist.

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