Winfield United v. Stoller Enterprises, Inc.
0:22-mc-00021
| D. Minnesota | May 13, 2022Background:
- Underlying patent litigation (Stoller v. Fine Agrochemicals) is pending in the Southern District of Texas; Stoller alleges defendants induced WinField to infringe Stoller’s plant-growth-regulator patents.
- Stoller served a subpoena duces tecum on nonparty WinField (Minnesota); WinField produced some documents but withheld others and invoked relevance limits and common-interest privilege; Stoller’s motion to compel those documents is pending in Texas.
- Stoller then served a Rule 30(b)(6) deposition subpoena on WinField to be taken in Minnesota before the close of fact discovery; WinField objected and filed a motion to quash in the District of Minnesota.
- Stoller opposed the quash and asked the Minnesota court to transfer the dispute to the issuing court (S.D. Tex.) under Fed. R. Civ. P. 45(f).
- The Minnesota magistrate judge found exceptional circumstances (case complexity, overlapping discovery disputes, risk of inconsistent rulings, and limited burden on WinField) and transferred the motion to the Southern District of Texas without ruling on the merits.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to transfer subpoena-dispute under Fed. R. Civ. P. 45(f) | Transfer to issuing court promotes efficiency and avoids disrupting case management | Opposes transfer; seeks local resolution to minimize travel/burden and preserve local forum | Transferred to S.D. Tex.; court found exceptional circumstances favor transfer |
| Whether "exceptional circumstances" exist to justify transfer | Case complexity, pending related motion in issuing court, risk of inconsistent rulings | No exceptional circumstances; local interests should control | Court found exceptional circumstances (complexity, overlapping issues, issuing court familiarity) |
| Whether transfer would unduly burden the nonparty | Transfer is not burdensome; WinField already has Texas counsel and local counsel may appear in issuing court | Transfer imposes burden on nonparty litigating out-of-district | Court held burden to WinField would be minimal and outweighed by efficiencies |
| Whether to decide motion to quash on the merits in Minnesota | Stoller opposed quash and urged denial | WinField sought quash of deposition subpoena | Court did not rule on the motion to quash and instead transferred the dispute |
Key Cases Cited:
- In re Disposable Contact Lens Antitrust Litig., 306 F. Supp. 3d 372 (D.D.C. 2017) (discussing factors and balancing test for Rule 45(f) transfer)
- Judicial Watch, Inc. v. Valle Del Sol, Inc., 307 F.R.D. 30 (D.D.C. 2014) (identifying considerations for transfer of subpoena-related motions under Rule 45(f))