Wood v. Capital One Services, LLC

Wood (plaintiff) sued Capital One and its debt-collection contractors (defendants) under the FDCPA, alleging a collection notice deceptively implied a lawsuit was imminent. After the defendants had already produced thousands of pages of documents and Rule 30(b)(6) witnesses, Wood moved to compel extensive additional email searches — dozens of email accounts across numerous search terms — to prove the notice was sent on one defendant's behalf. Services estimated compliance would cost over $5 million; both defendants moved for protective orders.

Whether a federal court may limit a party's requests for electronic discovery if the burden of production significantly outweighs its benefits.