BYTE FEDERAL, INC.
v.
LUX VENDING LLC
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In this discovery dispute, the District Court ruled on whether Defendants' Common Interest Agreement must be produced in response to a discovery request for all contracts and agreements. The Court concluded that the agreement, containing only standard joint defense language, was not relevant to any claim or defense and therefore need not be produced.
The Court held that the Common Interest Agreement is not relevant to any claim or defense in the litigation because it contains only standard, boilerplate joint defense language establishing terms for sharing privileged information, with no substantive information or other purposes. Therefore, the agreement need not be produced, and Plaintiff's Motion to Compel is denied.
[1] A joint defense or common interest agreement containing only standard, boilerplate language is not relevant for discovery purposes.
[2] The relevancy of a joint defense agreement depends upon the specific language contained within the agreement.
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The Court's conclusion that the agreement lacks relevance to any claim or defense in the litigation based on its nature as a pure joint defense agreement.
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Join FLexlaw to unlock all legal intelligencePlaintiff Byte Federal, Inc. filed a Motion to Compel seeking production of a joint defense agreement entered into by Defendants Lux Vending LLC, The …
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This cause comes before the Court upon review of Defendants' Common Interest Agreement (the “Agreement"), submitted by Defendant Huddled Masses, Inc. (“Huddled Masses") for in camera review. Initially, Plaintiff filed a Motion to Compel (Doc. 86), which sought, in part, production of a joint defense agreement entered into by Defendants because the document was responsive to Request for Production No. 4, which sought "[a]ll contracts and agreements that [Huddled Masses] entered into with Bitcoin Depot." (Doc. 86-1). Huddled Masses responded in opposition (Doc. 87), arguing that the Agreement was privileged and not relevant. The Court issued an Order granting in part and denying in part Plaintiff's Motion to Compel (Doc. 103). In that Order, the Court directed Huddled Masses to submit the Agreement to the Court for an in camera review. See, e.g., In re Takata Airbag Prods. Liability Litig., No. 15-02599, 2017 WL 10351709, at *2–3 (S.D. Fla. Mar. 7, 2017) (finding in camera review of joint defense agreement to be necessary and warranted because it is inappropriate to exclusively rely on one party's characterization of the disputed document and "the relevancy of a joint defense agreement depends upon the language in the agreement"). Huddled Masses timely provided the agreement to the Court.
The undersigned has carefully reviewed the Agreement, and concludes that it is properly characterized as a joint defense or common interest agreement, and as such, is not relevant. [fn 1] The Agreement contains standard, boilerplate joint-defense language, which establishes the terms, conditions, and limitations for the sharing of privileged and confidential information. The Agreement contains no other terms and does not serve multiple purposes. Because the Agreement does not include any substantive information and only contains typical joint defense language, the Court concludes that it is not relevant to any claim or defense in this matter. See Takata, 2017 WL 10351709, at *3-4 (finding standard joint defense agreement not be relevant); Biovail Labs. Int'l SRL v. Watson Pharms., Inc., No. 1:10-cv-20526, 2010 WL 3447187, at *1 (S.D. Fla. Aug. 30, 2010) (same).
Accordingly, it is hereby ORDERED: (1) As to the remaining issue regarding Defendants' Common Interest Agreement, Plaintiff's Motion to Compel (Doc. 86) is DENIED.
ORDERED in Tampa, Florida, May 17, 2024.
SEAN P. FLYNN
UNITED STATES MAGISTRATE JUDGE
[fn 1]: The Court need not determine whether the Agreement is privileged because the issue “can be resolved on a threshold issue—whether the agreement is even relevant for discovery purposes." Biovail Labs. Int'l SRL v. Watson Pharms., Inc., No. 1:10-cv-20526, 2010 WL 3447187, at *1 (S.D. Fla. Aug. 30, 2010).
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Byte Fed., Inc. v. Lux Vending LLC, 2017 WL 10351709 (M.D. Fla. 2024)…in part and denying in part Plaintiff's Motion to Compel (Doc. 103). In that Order, the Court directed Huddled Masses to submit the Agreement to the Court for an in camera review. See, e.g., In re Takata Airbag Prods. Liability Litig., No. 15-02599, 2017 WL 10351709, at *2–3 (S.D. Fla. Mar. 7, 2017) (finding in camera review of joint defense agreement to be necessary and warranted because it is inappropriate to exclusively rely on one party's characterization of the disputed document ---PAGE 2--- Case 8:23-cv-0…1 / 2
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Byte Fed., Inc. v. Lux Vending LLC (M.D. Fla. 2024)
Authorities Cited
- Byte Fed., Inc. v. Lux Vending LLC, 2017 WL 10351709 (M.D. Fla. 2024)