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ARTICLE · 07 JANUARY 2026

What A New Rule 34 Ruling May Tell Us About Navigating EDiscovery Of Dynamic Databases

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In Sound Around, Inc. v. Moises Friedman, Magistrate Judge Katharine A. Parker addressed Rule 34 standards relating to the production of structured data from dynamic databases.

United StatesLitigation, Mediation & Arbitration
Kathryn C. Cole
Kathryn C. Cole

In Sound Around, Inc. v. Moises Friedman, Magistrate Judge Katharine A. Parker addressed Rule 34 standards relating to the production of structured data from dynamic databases. Plaintiff filed a robust complaint alleging the defendants misappropriated confidential trade secret information, diverted corporate opportunities, used plaintiff's trademarks and overall commercial image and appearance (i.e., trade dress) to market competing products, and stole “hundreds of thousands (if not millions) of dollars from the company to build their business, pay their personal debts and expenses, and compete directly with” plaintiff. Defendants counterclaimed for the value of several commissions purportedly owed them by plaintiff.

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