Case Law

Court Limits Excessive Redactions in Non-Responsive Data

Wisconsin

IDC Fin. Pub., Inc. v. Bonddesk Grp., LLC, No. 15-cv-1085-pp, 2017 WL 4863202 (E.D. Wis. Oct. 26, 2017) In this contract dispute, the Court granted Plaintiff’s motion to compel production of documents Defendants had previously produced heavily redacted, 30 of 37 pages in one exhibit. Defendants argued that the redactions protected confidential business information not relevant to the dispute, citing In re Takata Airbag Prods. Liab. Litig., 14-24009-CV-MORENO, 2016 WL 1460143 (S.D. Fla. Feb. 24, 2016). In its decision, the Court cited Burris v. Versa Prods., Inc., No. 07-3938 (JRT/JJK), 2013 WL 608742 (D. Minn. Feb. 19, 2013), noting that the Federal Rules of Civil Procedure do not support the practice of redacting for non-responsiveness or irrelevance and that the potential for abuse exists in this instance.

Keywords: Redactions, production, non-responsive, In re Takata Airbag Prods. Liab. Litig., Burris v. Versa Prods. Inc., FRCP 26(b)(1), proportionality