Zenith Elecs., Inc. v. Vizio, Inc., 2009 WL 3094889 (S.D.N.Y. Sept. 25, 2009)

Key Insight: Court denied motion to compel production of documents by non-party pursuant to subpoena where court determined non-party did not have control of the documents requested because such documents were maintained by foreign parent company and non-party did not have access to them in the ordinary course of business

Nature of Case: Patent infringement

Electronic Data Involved: ESI, source code