Pop Top Corp v. Rakuten Kobo Inc.
4:20-cv-04482
| N.D. Cal. | Jul 25, 2025Background
- Judgment Debtor Rohit Chandra, representing himself, challenged post-judgment discovery requests made by Rakuten Kobo, Inc. (Kobo) after being added to a case as a judgment debtor.
- Chandra previously moved to quash the discovery, which was denied by the court on June 23, 2025.
- He then moved to vacate (construed as a motion for reconsideration), arguing new evidence and alleged misconduct.
- Chandra also filed a motion seeking formal admonishment of Kobo’s counsel for purported procedural abuse during discovery.
- Both motions were submitted without oral argument; the court found both lacked merit and denied them.
Issues
| Issue | Chandra's Argument | Kobo's Argument | Held |
|---|---|---|---|
| Citation of Non-Existent Cases | Errors were inadvertent and due to reliance on AI; pro se status warrants leniency | Chandra’s citations are unreliable and misleading | Warnings issued; no sanctions (yet) |
| Reconsideration of Order Denying Motion | Court relied on falsehoods, ignored key evidence, failed to protect pro se litigants | No basis for reconsideration; ample opportunity to respond | Denied: no grounds established |
| Sufficiency of Evidence for Discovery | Discovery sought is duplicative, burdensome, and already answered | Further discovery on Chandra’s finances is valid | Kobo entitled to continued discovery |
| Admonishment of Opposing Counsel | Defense counsel abused procedure by demanding discovery during a pending motion | No misconduct; Chandra never sought a stay or protection | No admonition warranted |
Key Cases Cited
- Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (establishes court’s inherent power to sanction bad faith or abusive practices)
- Fink v. Gomez, 239 F.3d 989 (9th Cir. 2001) (defining bad faith standard for sanctions)
- Munoz v. United States, 28 F.4th 973 (9th Cir. 2022) (pro se litigants must comply with same procedural rules as represented parties)