Shenzhenshi Yiranxin Technology Co., Ltd. v. Partnerships and Unincorporated Associations Identified on Schedule “A”
- Proceeding
- district
- Area
- civil
- Panel
- Michael S. Berg (author)
Analysis
Plaintiff Shenzhenshi Yiranxin Technology Co., Ltd. moved for limited jurisdictional discovery to identify defendants and establish personal jurisdiction. The court denied the motion because the plaintiff failed to show good cause, did not limit discovery to jurisdictional facts, and sought discovery from defendants who had already defaulted.
| What the court decided | The model |
|---|---|
Motion for Limited Jurisdictional Discovery denied“Based on the foregoing, Plaintiff's Motion is DENIED.” | agree with court The court correctly applied the 'good cause' standard for pre-Rule 26(f) discovery. The plaintiff failed to demonstrate that it had taken sufficient steps to identify the defendants, failed to show that the proposed discovery was limited to facts necessary for service, and failed to show that the discovery would likely lead to identifying information. Additionally, the court noted the practical futility of serving discovery on defendants who had already defaulted. The denial is supported by the cited authorities and the record. |
The order itself: sound — The order is sound. It correctly identifies the legal standard for limited jurisdictional discovery, applies the four-factor test from National Products, and finds that the plaintiff failed to satisfy key factors (steps taken, likelihood of success, and scope of discovery). The court also correctly notes the practical issue of seeking discovery from defaulting defendants. The reasoning is complete and supported by the cited authorities.
Opinion
2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 SHENZHENSHI YIRANXIN TECHNOLOGY Case No.: 25-cv-1991-GPC-MSB CO., LTD., 12 ORDER DENYING MOTION FOR LIMITED Plaintiff, 13 JURISDICTIONAL DISCOVERY v. 14 ECF NO. 21 PARTNERSHIPS AND UNINCORPORATED 15 ASSOCIATIONS IDENTIFIED ON SCHEDULE 16 “A”, 17 Defendants. 18 19 On September 4, 2026, Plaintiff Shenzhenshi Yiranxin Technology Co., Ltd. filed a 20 Motion for Limited Jurisdictional Discovery (“Motion”).1 ECF No. 21. The Court ordered 21 Plaintiff’s counsel to appear for a Discovery Conference regarding the Motion on 22 September 16, 2026, at 9:30 a.m. but counsel failed to appear. ECF Nos. 22-23. 23 I. Background 24 On July 9, 2026, the Hon. Gonzalo P. Curiel denied Plaintiff’s Motion for Default 25 Judgment and Permanent Injunction because “Plaintiff has not shown that this Court 26 27 2 for Default Judgment”). ECF No. 18 at 13. The Court adopts and incorporates the factual 3 and procedural background set forth in the July 9, 2026 Order Denying Plaintiff’s Motion 4 for Default Judgment. Id. at 1-4. 5 II. Legal Standard 6 Generally, formal discovery is not permitted before the parties have conferred 7 pursuant to Federal Rule of Civil Procedure 26(f). Fed. R. Civ. P. 26(d)(1). Courts, 8 however, have made exceptions “in rare cases . . . permitting limited discovery to ensue 9 after filing of the complaint to permit the plaintiff to learn the identifying facts 10 necessary to permit service on the defendant.” Columbia Ins. Co. v. Seescandy.com, 185 11 F.R.D. 573, 577 (N.D. Cal. 1999) (internal citations omitted). A plaintiff must show “good 12 cause” for such early discovery. Yokohama Tire Corp. v. Dealers Tire Supply, Inc., 202 13 F.R.D. 612, 613-14 (D. Ariz. 2001) (collecting cases and standards). In evaluating whether 14 a plaintiff establishes good cause for early discovery, courts must examine whether the 15 plaintiff 16 (1) identifies the defendant with sufficient specificity that the Court can determine that the defendant is a real person who can be sued in federal court, 17 18 (2) recounts the steps taken to locate and identify the defendant, 19 (3) demonstrates the action can withstand a motion to dismiss, and 20 (4) proves that the discovery is likely to lead to identifying information that will 21 permit service of process. 22 23 Nat'l Prods., Inc. v. Does 1-4, No. C16-0702JLR, 2016 WL 2989971, at *2 (W.D. Wash. 24 May 23, 2016); Columbia Ins. Co., 185 F.R.D. at 578-80. 25 III. Discussion 26 Plaintiff “moves for an order permitting limited jurisdictional discovery concerning 27 Defendants’ contacts with California and the United States, including information 2 state and, if not, whether personal jurisdiction exists under Federal Rule of Civil 3 Procedure 4(k)(2).” ECF No. 21 at 1-2. 4 Plaintiff, however, does not explain what “steps [it has] taken to locate or identify 5 the defendant.” See Nat'l Prods., Inc., 2016 WL 2989971, at *2 (finding plaintiff took 6 sufficient steps to locate and identify John Doe defendants alleged to have sold 7 infringing products through Amazon.com storefronts where plaintiff “repeatedly 8 contacted Amazon.com, explaining the legal basis for [its] claims and requesting that 9 Amazon.com identify John Does 1-4”). 10 Nor has Plaintiff shown “that the discovery is likely to lead to identifying 11 information.” See id. (finding plaintiff’s proposed Federal Rule of Civil Procedure 45 12 subpoena to third-party Amazon.com requested “identifying information that [would] 13 allow [plaintiff] to accomplish service of process on John Does 1-4” where plaintiff 14 showed the Doe defendants “have contractual relationships with Amazon.com and are 15 responsible for making payments to Amazon.com associated with their sales on 16 Amazon.com’s website”). Plaintiff’s proposed document requests, however, are not 17 limited to discovering only facts necessary to establish jurisdiction. See ECF No. 21 at 15- 18 18 (proposed Requests for Production requesting documents for subject matters other 19 than Defendant(s) true identity(ies), place(s) of business, whether they have sold 20 products in the United States and, if so, which states they have shipped products to). 21 Moreover, Plaintiff seeks to propound these document requests to Defendants against 22 whom default has been entered. Id. at 15-18. It is unlikely defendants that did not 23 respond to a summons and complaint will respond to document requests. 24 / / 25 / / 26 / / 27 / / 1 IV. Conclusion 2 Based on the foregoing, Plaintiff's Motion is DENIED. Nat'l Prods., Inc., 2016 WL 3 2989971, at *2. 4 IT IS SO ORDERED. 5 || SO ORDERED. 6 ||Dated: September 18, 2026 3 Honorable Michael S. Berg United States Magistrate Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28