B. DigEcor’s Subpoenas Should Be Quashed As Overly Broad, Unduly Burdensome, and Seeking Disclosure of Confidential Commercial Information.

CONCLUSION

If digEcor believes that the non-parties in question might possess a specific kind or category of documents that are relevant to this case, it is permitted under the rules to request them. However, the law is clear that "fishing expeditions" are not allowed, especially in the instance of subpoenas served on non-parties. See Convergys Corp., Slip Copy, 2007 WL 474012, *1 (D. Utah 2007); Jackson v. AFSCME Local 196, 246 F.R.D. 410, 415 (D. Conn. 2007). digEcor has served, without notice, and on four of e.Digital’s valued customers, a set of requests seeking every document in the e.Digital universe in the hopes of finding anything at all relevant to the limited facts in question here. These requests impose an enormous burden, are far too broad in scope and time, and require the disclosure of confidential commercial information. For all of these reasons, the subpoenas should be quashed or substantially modified, or an acceptable protective order put in place.