Machinery Solutions, Inc. v. Doosan Corporation
3:15-cv-03447
D.S.C.Jan 26, 2018Background
- MSI (Machinery Solutions, Inc.) alleges Doosan terminated its distributor agreement and contracted with Ellison as a new dealer for Doosan machine tools covering NC, SC, and GA; MSI sued Doosan and Ellison for various state-law claims and removed to federal court on diversity grounds.
- Doosan’s August 21, 2015 letter terminated the Distributor Agreement with a 30‑day transition and identified Ellison as the successor dealer effective Sept. 1, 2015.
- After partial defenses and motions to dismiss, MSI served discovery on Ellison and moved to compel responses and production (Motion to Compel, ECF No. 131). Many disputes were later partially resolved by the parties.
- Remaining disputes before the court involved: Interrogatory No. 10 (efforts discouraging suppliers from selling parts), Interrogatory No. 11 (documents reflecting Ellison’s expected profit from Doosan sales), and MSI’s broad request to compel documents Ellison withheld as irrelevant (general discussions about replacing dealers).
- The court applied Rule 26’s relevance/proportionality framework and Rule 37 motion-to-compel principles to decide which discovery responses must be supplemented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Interrogatory No. 10 — efforts discouraging suppliers from selling parts | MSI seeks all efforts discouraging suppliers from selling/shipping parts to U.S. customers to support its conspiracy/antagonizing parts access theory | Ellison says the interrogatory is vague, overbroad, unduly burdensome, and seeks irrelevant third‑party conduct | Granted in part: Ellison must produce efforts it took to discourage suppliers from selling parts to MSI (limited scope) by Feb 8, 2018; broader requests as to other parties denied as overbroad and irrelevant |
| Interrogatory No. 11 — documents reflecting Ellison’s expected profit from Doosan sales | MSI seeks documents showing Ellison’s profit calculations for Doosan machine sales (Jan 1, 2015–Sept 30, 2016) | Ellison says it already produced sales projections/budgets and contends additional material is not relevant; no indication more responsive documents exist | Denied without prejudice: court won’t compel production absent evidence additional responsive documents exist; MSI may move again if it can substantiate existence of such documents |
| Production of documents Ellison withheld as irrelevant (general ‘dealer replacement’ discussions) | MSI contends general discussions about replacing dealers are relevant and were improperly withheld as irrelevant | Ellison withheld unspecified documents as not relevant | Denied: MSI’s request was too general and did not identify specific required disclosures under Rule 26; court declined to grant a broad order to produce all documents labeled ‘irrelevant’ |
| Procedural scope and burden/proportionality | MSI argues the requests are proportional and needed to develop its case | Ellison argues burden, vagueness, and lack of relevance for broad categories | Court applied Rule 26 balancing: narrowed scope where proportional and relevant; declined to order production of nonexistent or unsupported materials |
Key Cases Cited
- National Union Fire Ins. Co. of Pittsburgh, P.A. v. Murray Sheet Metal Co., Inc., 967 F.2d 980 (4th Cir. 1992) (discovery rules construed broadly to allow information reasonably necessary to develop a case)
- Hickman v. Taylor, 329 U.S. 495 (1947) (discovery should be given liberal treatment but is not limitless)
- Lone Star Steakhouse & Saloon, Inc. v. Alpha of Va., Inc., 43 F.3d 922 (4th Cir. 1995) (district court has broad discretion in managing discovery and in ruling on motions to compel)