In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation

District Court, N.D. Illinois·Decided July 22, 2025·No. 1:23-cv-00818·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

IN RE: HAIR RELAXER MARKETING MDL No. 3060 SALES PRACTICES AND PRODUCTS LIABILITY LITIGATION Master Docket No. 23-cv-0818 Judge Mary M. Rowland MEMORANDUM OPINION AND ORDER Defendants Revlon, Inc., Revlon Consumer Products Corporation, and Revlon

Group Holdings LLC (collectively, “Defendant” or “Revlon”) move to compel the National Institutes of Health (“NIH”) to comply with a subpoena for documents issued in connection with this MDL. For the reasons stated herein, Revlon’s motion is denied. I. Background NIH funded and its researchers authored two studies that correlated hair relaxer use with higher rates of ovarian and uterine cancers. See Alexandra J. White,

et al., Use of hair products in relation to ovarian cancer risk, Carcinogenesis, 42:1189- 1195 (2021), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8561257/ (“White Study”); Che-Jung Chang, et al., Use of Straighteners and Other Hair Products and Incident Uterine Cancer, Journal of the National Cancer Institute, Oct. 17 (2022), https://pubmed.ncbi.nlm.nih.gov/36245087 (“Chang Study”) (collectively the “NIH studies”). Plaintiffs’ Master Long Form Complaint relies on and cites to the NIH studies. [106] ¶¶ 85–91. On February 14, 2024, Revlon issued a subpoena to NIH. See [1034-1]. Following meet-and-confers, Revlon narrowed its requests and is seeking the

production of: (1) all “data collected, compiled, or created” for the studies; (2) any correspondence between NIH or the study authors and plaintiffs’ counsel; (3) all “drafts, versions, and releases” of the Chang and White Studies; and (4) any “documents, work papers, and communications . . . reflecting any analysis of the” study data by its authors. [1034-1] at 10–11. On July 24, 2024, this Court entered an agreed protective order to govern the production of documents from NIH. See [777].

NIH has agreed to produce the study data and communications between the NIH or the study authors and Plaintiffs’ counsel. [1034] at 3; [1185] at 1–2. To date, NIH has produced the study data and at least some communications with Plaintiff’s counsel.1 [1034] at 3; [1185] at 1–2. NIH contends all internal documents and correspondence, including work papers, drafts, and analyses related to the studies, are protected by the deliberative process privilege. See [1185]. Revlon moved to compel on the grounds that NIH’s assertion of the privilege is overbroad and even if

the privilege did apply, the requested documents nevertheless should be produced. NIH disagrees.2

1 NIH produced a privilege log of the withheld study drafts with its response to Revlon’s motion to compel. [1185] at 18–27. NIH reports it has not completed its search for or review of communications and requests the court allow time for NIH to prepare a log asserting privilege on a more individualized basis if the Court is inclined to grant Revlon’s motion. Id. at 12. Revlon disputes the log provides sufficient information to evaluate NIH’s privilege assertions. [1224] at 8. 2 The MDL Plaintiffs oppose Revlon’s motion to compel on the grounds that the subpoena seeks private medical information, imposes an undue burden on a non-party, and will chill scientific research. See [1190]. Revlon requests the Court strike Plaintiffs’ brief as untimely, for lack of standing, and as II. Standard District courts have broad discretion in supervising discovery and ruling on discovery motions. Cent. States, Se. & Sw. Areas Pension Fund v. Waste Mgmt. of

Mich., Inc., 674 F.3d 630, 636 (7th Cir. 2012). “In ruling on motions to compel discovery, courts have consistently adopted a liberal interpretation of the discovery rules.” Kodish v. Oakbrook Terrace Fire Prot. Dist., 235 F.R.D. 447, 450 (N.D. Ill. 2006) (citation omitted). Under Federal Rule of Civil Procedure 45, the scope of discovery that a party may seek in a subpoena is as broad as the rules of discovery allow. EEOC v. AutoZone,

Inc., 2016 WL 7231576, at *2 (N.D. Ill. Dec. 14, 2016). A subpoena may request information about “any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case ...” Fed. R. Civ. P. 26(b)(1). III. Analysis NIH argues the motion to compel must be denied for two reasons: (1) Revlon never properly served its subpoena on NIH and thus NIH has no legal obligation to produce documents; and (2) the deliberative process privilege protects the documents

Revlon seeks. In support of its motion, Revlon argues (1) NIH has not properly asserted the deliberative process privilege; (2) if NIH properly invoked the privilege,

procedurally improper. [1224] at 8, 19–20. A party may move to quash a subpoena directed at a third party if the subpoena “infringes upon the movant’s legitimate interests.” United States v. Raineri, 670 F.2d 702, 712 (7th Cir. 1982). Courts recognize a “legitimate interest” where the materials sought implicate “a claim of privilege, privacy, or other personal right.” Davis v. Nanny, 2018 WL 656597, at *2 (S.D. Ill. Feb. 1, 2018). Plaintiffs’ assertion of interest in the privacy of the health information of MDL Plaintiffs who participated in the NIH studies suffices to establish standing. HTG Cap. Partners, LLC v. Doe(s), 2015 WL 5611333, at *3 (N.D. Ill. Sept. 22, 2015) (finding standing where the claimed “privacy interest is minimal at best”). Accordingly, the Court declines to strike Plaintiffs’ brief. the assertion is overbroad; and (3) if the privilege does apply, Revlon has demonstrated a particularized need for the documents that NIH seeks to withhold. The Court addresses each of these arguments.

a. Service We begin with a procedural deficiency. NIH contends Revlon’s subpoena cannot be enforced because Revlon never properly served NIH. [1185] at 2–3. Pursuant to 45 C.F.R. § 4.2, subpoenas issued to the Department of Health and Human Services and the operating divisions within HHS, including NIH, must be either (a) mailed to HHS’s General Counsel; or (b) delivered in person to the staff of

the Office of Legal Resources. Here, Revlon did not mail or deliver in person the subpoena to the addresses set forth in the regulation, but instead it served NIH’s Chief of Staff. [1185] at 15 (Declaration of Paul J. Robertson ¶ 5 (“Robertson Decl.”)); [1224-1]. Absent proper service, NIH insists it has no legal obligation to produce records; and therefore, there are no valid grounds on which this Court can order compliance with the subpoena. [1185] at 2–3. Revlon asserts NIH waived this objection. [1224] at 17–18. Under Rule

45(d)(2)(B), a non-party served with a subpoena for documents must object “before the earlier of the time specified for compliance or 14 days after the subpoena is served.” See Ott v. City of Milwaukee, 682 F.3d 552, 558 (7th Cir. 2012) (quoting Fed. R. Civ. P. 45(d)(2)(B)). The deadline for NIH’s objection was February 29, 2024. [1224] at 18. The Court agrees with Revlon. NIH’s objection to service is too late. NIH did not raise this objection until over a year after service—well after the February 29, 2024 deadline set forth under Rule 45. [1224] at 17–18.

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In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation, (N.D. Ill. 2025).

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