Subsidiary Must Produce Parent Company's Financial Documents
The Eastern District of Missouri compelled production of the parent company's financial documents in Orthoarm, Inc. v. Forestadent USA, Inc., 2007 WL 1796214 (E.D. Mo. 6/19/07).
Orthoarm filed this patent infringement action against Forestadent USA. Orthoarm submitted discovery requests seeking financial documents of Forestadent Germany, Forestadent USA's parent company. Forestadent USA refused to produce the documents, claiming it did not have control of its parent company's financial documents.
The district court disagreed and issued an order compelling production of these documents. Guiding the court's analysis was the fact that the owners of Forestadent Germany are the officers and directors of Forestadent USA.
