*1 Plaintiff Karma Automotive LLC (“Karma”) moves for an order compelling production by Defendants of documents responsive to its RFPs 45, 60, and 107-113. See Dkt. 117 (“Motion”). Defendants oppose Karma's motion. See Dkt. 119. Karma's motion follows the parties' discussion of these and other RFPs with me in a series of informal discovery conferences. At the last conference, the parties agreed to brief their remaining disputes involving these RFPs.

During those discussions, I told the parties that I would be looking for a discussion of how these RFPs tied back to Karma's claims as identified in its FAC. See, e.g., Dkt. 120 at 33. Although this may be a large case in terms of the amount in controversy, I emphasized that even larger cases required some care to keep the scope of discovery manageable. See Dkt. 115 at 23 (“[W]e have to be focused and tailored in our approach or we run the risk of letting the case get away from the Court and counsel.”); Dkt. 120 at 25-26 (“I am concerned that the discovery in this case remain manageable ... [e]ven the largest case has Rule 1 and Rule 26 proportionality concerns.”). And as LMC points out, the amount in controversy is but one of several proportionality factors under Rule 26(b), which also include the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefits.

To determine whether Karma's RFPs sought information that was within the scope of discovery in light of those Rule 26(b) factors, I did what I said I would do, and looked at those requests against the allegations of the FAC about defendants' misappropriation of confidential and trade secret information to determine whether those allegations implicated the information sought by the RFPs. I did not look for direct links like references to specifically misappropriated documents; I agree with Karma that the scope of discovery cannot be tailored precisely to the documents specifically identified in the FAC. But I am wary of RFPs that find no basis in the FAC except for general and conclusory allegations. And for several of Karma's RFPs, its efforts to show that the RFPs sought information made relevant by the allegations of its FAC were unpersuasive.

RFP 60 seeks documents relating to agreements between LMC and third parties. Karma points to a conclusory allegations that defendants stole its confidential and trade secret information and used that information to build or improve upon nearly every aspect of its Endurance project to justify a wide-ranging inquiry into “whether and to what extent [LMC] used third-party vendors to develop these systems.” Motion at 8. But this is the kind of approach that I fear would open the door too broadly and cause the scope of discovery to become unmanageable. Karma's motion as to RFP 60 is accordingly DENIED.

Similarly, RFPs 108 and 111 seek LMC's program schedules and product planning documents based on Karma's general allegations that LMC's use of confidential information helped it expedite Endurance production while LMC faced heavy pressure from investors and others to move things along. See Motion at 9-10. Again, however, these broad requests are untethered to any specific confidential or trade secret information that LMC or other defendants are alleged to have stolen. Absent such a link, I cannot agree that discovery about every aspect of the Endurance project is warranted. Karma's Motion as to RFPs 108 and 11 is accordingly DENIED.

*2 Additionally, RFPs 109 and 110 seek documents related to LMC's vehicle testing and crash testing process. To justify these requests, Karma points to general allegations that LMC misappropriated its vehicle testing and crash testing and used them on the Endurance. See Motion at 10-11 (citing FAC ¶¶ 14, 110). But a review of those allegations shows no specific allegations of misappropriation related to vehicle testing or crash testing. Without more, I cannot agree that discovery about those topics would be proportional to the needs of this case. Karma's motion as to RFPs 109 and 110 is accordingly DENIED.

Karma finds more traction with RFP 113, which seeks information about LMC's bill of materials, or BOMs. Paragraphs 91(a) and (b) of the FAC allege specifically that one of the individual defendants misappropriated BOMs. And Karma has made other allegations of similar misappropriation. See Motion at 13 (citing Coleman Decl. ¶ 12). These allegations implicate at least some of LMC's BOMs. And thus I cannot agree with LMC that “neither company's bill of materials is relevant.” Opposition at 11. Instead, LMC suggests that BOMs be put on hold until the parties complete the production of documents under their forensic protocol. But it is not clear to me how that delay would be of any assistance in determining which of LMC's BOMs are implicated by Karma's allegations. Thus I am left with no suggestion from LMC about how to tailor Karma's request to make it proportional to the needs of the case. Given a choice between all-or-nothing, I must choose all, as Karma's allegations implicate at least some of LMC's BOMs. Karma's motion is accordingly GRANTED as to RFP 113 and LMC is ORDERED to produce all historical and current versions of its BOMs for any electric vehicle component within fourteen (14) days of the date of this order.

RFP 107 presents similar issues. It seeks documents about LMC's vehicle device transmittal functionality. Helpfully, Karma cites specific allegations of defendants' misappropriation to justify this request. See Motion at 9. But here the devil is in the details, as counsel's discussions with me and the parties' meet-and-confer correspondence reveal some discord about what categories of documents might be within the scope of RFP 107. Ultimately, that discussion tried to find some footing in an LMC spreadsheet that Karma suggested would serve as a guidepost for what documents would be within the scope of this request. This document was then submitted to me. My review of this spreadsheet reveals some references to items that are mentioned in the aforementioned allegations of the FAC (for example, “telematics,” or “CAN”). But there are also items in this spreadsheet that appear unrelated to any of Karma's allegations, such as entries for “passenger window motor” or “washer fluid level sensor.” Accordingly, I have reviewed the spreadsheet (LMC00159180) and identified the “Device Names” on that spreadsheet which appear to be related to the allegations Karma has identified. Karma's motion is GRANTED in part and LMC is ORDERED to produce “schematics, computer-assisted drawings, design documents, technical specifications, system requirements, system architecture, and component requirements” for the components identified in Lines 13, 41-84, 95, 98, 136, and 298-303 of LMC00159180 within fourteen (14) days of the date of this order.

Shifting gears, RFP 45 seeks LMC's financial statements. LMC has agreed to produce its audited, public financial statements. Karma seeks all LMC's financial statements, including unaudited financial statements as well as communications about those financial statements, under the theory that unaudited financials or communications about those financials might contain some discoverable information about defendants' misappropriation of Karma's trade secret and confidential information. But the chance that communications about those financial statements might shed some light on LMC's alleged use of Karma's confidential and trade secret information is speculative at best and a fishing expedition at worse. I cannot find that production of anything beyond the audited, public financials is warranted. Karma's motion as to RFP 45 is accordingly DENIED.