Kaan Ekiner, writing in the Delaware Business Court Insider, discusses Teal Communications v. Premier Wireless Solutions, 2025 WL 2597612 (Del. Super. Ct. Sept. 8, 2025), a case where the plaintiff, Teal Communications, Inc., filed a motion to quash or implement a protective order relating to twelve subpoenas issued by the defendant. Teal claimed that the subpoenas sought voluminous, irrelevant information that could have been obtained, if discoverable, in a more convenient and less burdensome manner from Teal. Premier opposed the motion on the basis that Teal lacks standing to dispute the subpoenas because they were issued to third parties. While the recent amendment to Rule 26(c) provides Delaware state court litigants with a more express avenue to challenge third-party subpoenas, limitations remain. Teal lacked standing to assert burden or relevance objections on behalf of the recipients. And the court found that Teal’s reputational arguments—designed to protect Teal’s relationship with its investors and customers—lacked merit.
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