Yoder & Frey Auctioneers, Inc. v. EquipmentFacts, LLC
774 F.3d 1065
| 6th Cir. | 2014Background
- Yoder & Frey Auctioneers hosts used construction equipment auctions, with a Florida auction being its largest event.
- Efacts provided online bidding platform services and retained confidential auction data during a prior relationship.
- In 2010, Yoder & Frey contracted RTB to run a custom platform for the Florida auction; Efacts allegedly accessed RTB’s platform without authorization.
- Effacts’ owner Garafola allegedly used a test login (bidder 100051) to place winning bids, and an Efacts employee used Allied Erecting’s identity (bidder 102703) to place multiple winning bids.
- Ten suspicious IP addresses tied to Efacts were traced to the company after investigating Allied Erecting’s bids; ISPs provided logs (IIS logs) showing access corresponding to those bidder numbers.
- A jury found in favor of Plaintiffs on their CFAA and related claims, leading to post-trial motions and sanctions at issue on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Spoliation sanctions standard applied | Efacts destroyed/failed to preserve evidence relevant to the logs. | District court improperly required more direct evidence of fault or error. | No abuse of discretion; sanctions denied. |
| Admissibility of ISP logs as business records | Logs satisfy Rule 803(6) requirements and are authentic. | Defendants argued insufficient foundation/authentication. | District court correctly admitted the ISP records under Rule 803(6). |
| CFAA damages and loss requirements | Efacts caused damage and loss by unauthorized access and financial investigation costs. | Plaintiffs failed to show loss from an interruption in service. | Sufficient evidence supported damage and loss; CFAA liability established. |
| Rule 37 sanctions for admissions | Efacts improperly denied admissions; sanctions appropriate. | Had reasonable grounds to contest; not sanctionable. | District court did not err in awarding sanctions; upheld. |
Key Cases Cited
- Beaven v. U.S. Dep’t of Justice, 622 F.3d 540 (0) (Beaven test for spoliation relevance)
- Automated Solutions Corp. v. Paragon Data Sys., Inc., 756 F.3d 504 (0) (sanctions and inference standards for spoliation)
- Adkins v. Wolever, 692 F.3d 499 (0) (standard for reviewing spoliation sanctions; Beaven framework)
- Radvansky v. City of Olmsted Falls, 496 F.3d 609 (0) (de novo review of Rule 50/Rule 37 issues on appeal)
- Nexans Wires S.A. v. Sark-USA, Inc., 166 F. App’x 559 (0) (loss under CFAA includes costs and revenue lost from interruption of service)