In what is another fascinating discovery dispute involving social media platforms, the court in In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation addressed a dispute between the defendants and several U.S. states pursuing consumer protection claims related to adolescent social media use. At the heart of the dispute is an amended Rule 30(b)(6) deposition notice to these states, requesting corporate representative testimony on various topics. The court reiterated that while discovery rules allow for broad relevance, discovery must remain proportional to the needs of the case. It emphasized the importance of limiting burdensome requests, particularly when state agencies are expected to designate knowledgeable witnesses on expansive or poorly defined topics.
Ultimately, the ruling allowed for 30(b)(6) testimony provided that deposition topics were more clearly defined. Most importantly, the court provided clarity on the scope of “Social Media Platforms” used in the defendant’s deposition topics. The court divided the topics into two categories: those directly related to adolescent use of social media and those that are not. For topics focused on youth usage, platforms like Facebook, Instagram, TikTok, Snapchat, YouTube, and Twitter/X were included. For broader topics unrelated to minors, the scope was restricted to Facebook and Instagram only. This approach balanced defense needs with the states’ concern over excessive discovery demands. The court also reiterated that simply including teens in a broader topic does not justify inclusion of all platforms. The court particularly addressed specific deposition topics and the limitations being imposed on those topics.
Overall, the court balanced the need for robust discovery with concerns about overreach and administrative burden, instituting procedural safeguards such as advance identification of documents and strict limits on questioning beyond those disclosures.
If your organization is seeking support with eDiscovery, our team has solutions to address all phases of the discovery process. At CODISCOVR, we deliver client-focused, defensible, and scalable solutions using advanced technology and intelligent review practices to meet eDiscovery, document review, and information governance needs in a manner that reduces the risks and costs associated with electronically stored information (ESI). Reach out to Nicole Gill, Chair, Managing Member CODISCOVR. With almost a decade of experience, she manages complex and high-profile eDiscovery projects and routinely navigates data and privacy protection laws across many domestic and foreign jurisdictions.
