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The motion argues Intuit exists no dispute about the CRM database and data, but Intuit objected, refused production, and later asserted the production deadline had passed after negotiations stalled. The filing also explains related relevance to Intuit’s defenses based on customer satisfaction scores and the proportion of complaint volume, and describes efforts to secure production via multiple meet-and-confer sessions and email communications.",{"@graph":14,"@context":72},[15,34,55],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/letters/","Letters",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/complaint-counsels-motion-to-compel-production-of-documents-publicpdf/303623/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/complaint-counsels-motion-to-compel-production-of-documents-publicpdf/303623.png","ImageObject",442,249,{"name":42,"@type":43},"Liam","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-09-27","2026-09-19",true,{"@type":52,"interactionType":53,"userInteractionCount":33},"InteractionCounter",{"@type":54},"ViewAction",{"@type":56,"mainEntity":57},"FAQPage",[58,64,68],{"name":59,"@type":60,"acceptedAnswer":61},"What is Complaint Counsel asking the court to do?","Question",{"text":62,"@type":63},"Complaint Counsel asks the court to compel Intuit to produce responsive documents and CRM data under Request for Production No. 22.","Answer",{"name":65,"@type":60,"acceptedAnswer":66},"What information does Request 22 seek?",{"text":67,"@type":63},"Request 22 seeks data in Intuit’s CRM database (or any database used to maintain customer information, feedback, complaints, and/or sales) related to the issues in the case.",{"name":69,"@type":60,"acceptedAnswer":70},"Why does the motion argue Intuit’s refusal should not be permitted?",{"text":71,"@type":63},"The motion argues there is no dispute that the CRM data exists, that negotiations failed only after impasse, and that Intuit’s “too late/waiver” position reflects improper gamesmanship rather than a legitimate basis to refuse production.","https://schema.org",{"og:url":32,"og:type":74,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":76,"canonical":32},"index,follow",{"doc_id":78,"site_id":7},303623,1790213076,{"code":4,"msg":81,"data":82},"success",[83,88,93,98,103,108,113,117,122],{"id":84,"doc_module":22,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},11,"Presentations",90,"presentations",{"id":89,"doc_module":22,"doc_module_name":25,"category_name":90,"show_sort_weight":91,"slug":92},12,"Resumes",80,"resumes",{"id":94,"doc_module":22,"doc_module_name":25,"category_name":95,"show_sort_weight":96,"slug":97},14,"Invoices",70,"invoices",{"id":99,"doc_module":22,"doc_module_name":25,"category_name":100,"show_sort_weight":101,"slug":102},15,"Posters",60,"posters",{"id":104,"doc_module":22,"doc_module_name":25,"category_name":105,"show_sort_weight":106,"slug":107},16,"Social Media",50,"social-media",{"id":109,"doc_module":22,"doc_module_name":25,"category_name":110,"show_sort_weight":111,"slug":112},17,"Forms",40,"forms",{"id":114,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":115,"slug":116},18,30,"letters",{"id":118,"doc_module":22,"doc_module_name":25,"category_name":119,"show_sort_weight":120,"slug":121},21,"Paper Templates",5,"papers-templates",{"id":123,"doc_module":22,"doc_module_name":25,"category_name":124,"show_sort_weight":4,"slug":125},158,"General","general-158",{"code":4,"msg":81,"data":127},{"doc_id":78,"user_id":128,"nickname":42,"user_avatar":129,"doc_module":22,"category_id":114,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":33,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":135,"language":136,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":12,"update_tm":140,"read_time":141},8796095461564,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 12/12/2022 | Document No. 606416 | PAGE Page 1 of 123 * PUBLIC *;  \nPublic  \nUNITED STATES OF AMERICA  \nBEFORE THE FEDERAL TRADE COMMISSION  \nOFFICE OF ADMINISTRATIVE LAW JUDGES  \nIn the matter of:  \nIntuit Inc.,  \na corporation, Respondent.  \nDocket No. 9408  \nCOMPLAINT COUNSEL’S MOTION TO COMPEL PRODUCTION OF  \nDOCUMENTS  \nComplaint Counsel, pursuant to Rules of Practice 3.37 and 3.38, moves for an order to compel Respondent Intuit Inc. (“Intuit”) to produce data responsive to Request for Production No. 22 (the “Request”), initially served on Intuit on September 12, 2022. The Request seeks information contained in Intuit’s consumer relationship management database (the “CRM”) pertaining to actual or potential customers who interacted with TurboTax’s free product or offer, including records of those consumers’ complaints and other negative feedback. There is no dispute that the CRM data exists. Instead, Intuit first objected to the Request and refused to produce any responsive documents, and now, after reaching an impasse in negotiations, argues that the clock has run out to secure production. This Court should not permit such gamesmanship and should instead compel Intuit to produce the requested documents.  \nI. Statement of Facts  \nOn September 12, 2022, Complaint Counsel issued its First Set of Requests for Production of Documents to Intuit Inc. GX-476 Decl. of R. Anguizola, Dec. 9, 2022, at ¶  \n4. Request 19 seeks documents related to complaints or other negative feedback from consumers or potential consumers who expected to file their taxes for free using TurboTax but were not eligible to do so, while Request 22 seeks related data “contained in your customer relationship management database (“CRM”), or any database(s) used  \nFEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 12/12/2022 | Document No. 606416 | PAGE Page 2 of 123 * PUBLIC *;  \nPublic  \nto maintain customer and potential customer information, feedback, complaints and/or sales.” Id. Such requests are of a sort routinely sought—and obtained—from companies in deception cases. In addition to the general relevance of consumer complaints in a case about whether consumers were deceived by Intuit’s advertising, the Requests also relate directly to Intuit’s own defenses – namely that TurboTax has high customer satisfaction scores, ergo consumers are not being deceived. For example, in its Opposition to Complaint Counsel’s Motion for Summary Decision, Intuit relies on TurboTax’s “high customer-satisfaction scores” as evidence that there is no violation of the FTC Act. Respondent’s Opposition to Motion for Summary Decision, August 30, 2022, at 19. Rather than taking it from the horse’s mouth, however, Requests 19 and 22 would allow the Complaint Counsel to probe that defense. Intuit also makes a related argument that the consumer complaints identified by Complaint Counsel “represent a miniscule proportion of TurboTax customers, compared to the significant number of consumers who have rated TurboTax highly.” Id. at 9. And while Complaint Counsel disputes the conclusion Intuit draws from the volume of the consumer complaints produced to Intuit in this matter, its CRM data provides a potential repository of additional complaints regarding the marketing practices at issue in this case.  \nOn October 3, 2022, Intuit served its Responses and Objections, agreeing, with respect to Request 19, to produce responsive documents that “discuss customer complaints and feedback from consumers who indicated that they believed from advertisements that they could file their taxes for free using TurboTax Free Edition but were not eligible to do so.” [Id](Id. at)[. at](Id. at) ¶ 6. (The phrase “from advertisements” is a limiting phrase added by Intuit and the appropriateness of which Complaint Counsel disputes) . With respect to Request 22, however, Intuit flatly refused to produce any data from the CRM database, arguing tha","cbCaig45IaW41Up5","https://ap.wps.com/l/cbCaig45IaW41Up5","pdf",3457902,123,"English","# Statement of Facts\n## Procedural history and requests\n## Negotiations and Intuit’s refusal\n# Argument\n## Discovery scope and relevance","[{\"question\":\"What is Complaint Counsel asking the court to do?\",\"answer\":\"Complaint Counsel asks the court to compel Intuit to produce responsive documents and CRM data under Request for Production No. 22.\"},{\"question\":\"What information does Request 22 seek?\",\"answer\":\"Request 22 seeks data in Intuit’s CRM database (or any database used to maintain customer information, feedback, complaints, and/or sales) related to the issues in the case.\"},{\"question\":\"Why does the motion argue Intuit’s refusal should not be permitted?\",\"answer\":\"The motion argues there is no dispute that the CRM data exists, that negotiations failed only after impasse, and that Intuit’s “too late/waiver” position reflects improper gamesmanship rather than a legitimate basis to refuse production.\"}]","complaint counsel’s motion to compel production of documents - public.pdf | PDF",1789805744,43]