Document Requests from Copyright Owner
(Plaintiff) to Alleged Infringer (Defendant)

Summary

This template for document requests under Fed. R. Civ. P. 26(b)(1) and 34 may be used by a plaintiff in a copyright litigation in federal district court. This template includes practical guidance, drafting notes, and alternate and optional clauses. The term Plaintiff's Work is used to mean the copyright-protected work that the plaintiff asserts has been infringed. The term Accused Work refers to the defendant's accused work. Rule 34 permits a party in a federal lawsuit to serve on other parties requests to: • produce or permit inspection of designated documents, or electronically stored information (ESI) • produce or permit inspection of designated tangible things – and – • permit entry on designated land or property for inspection, measurement, or the like See Fed. R. Civ. P. 34(a)(1) & (a)(2). When preparing document requests, keep in mind Rule 26(b)(1)'s guidance on the scope, limits, and proportionality of party discovery. You are entitled to discover information relevant to any ...