Abbott Laboratories v. Revitalyte LLC

U.S. District Court, District of Minnesota

Abbott Laboratories v. Revitalyte LLC

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Abbott Laboratories,                    Civil No. 23-1449 (DWF/DTS)      

               Plaintiff,                                                

v.                                               MEMORANDUM              
                                            OPINION AND ORDER            
Revitalyte LLC,                                                          

               Defendant.                                                


                        INTRODUCTION                                     
    This matter is before the Court on Defendant Revitalyte LLC’s (“Revitalyte”) 
objections (Doc. No. 93) to Magistrate Judge David T. Schultz’s order on October 23, 
2024 (Doc. No. 91 (articulated in Doc. No. 92 (“Hr’g Tr.”))).  Plaintiff Abbott 
Laboratories (“Abbott”) filed a response.  (Doc. No. 96.)  For the reasons set forth below, 
the Court sustains in part and overrules in part Revitalyte’s objections.  Accordingly, the 
Magistrate Judge’s order is affirmed in part and respectfully modified in part. 
                         BACKGROUND                                      
    Abbott brings state law and federal law claims of trade dress infringement, 
trademark infringement, unfair competition, false designation of origin, false advertising, 
and trademark and trade dress dilution by tarnishment against Revitalyte.  (Doc. No. 22 
(“Am. Compl.”) ¶¶ 170-203.)  Revitalyte served twenty-three interrogatories and sixty-
two requests for production on Abbott.  (Doc. No. 73 (“Hallerman Decl.”) Ex. A at 7-12; 
id. Ex. C at 48-59.)  Abbott objected to each of these requests for a litany of reasons and 
refused to respond to six interrogatories and thirty requests for production.  (Hallerman 
Decl. Exs. B, D.)  Revitalyte moved to compel Abbott to respond fully to nine 
interrogatories and twenty requests for production.  (Doc. No. 72.)  Abbott opposed each.  

(Doc. No. 85.)  Magistrate Judge David T. Schultz granted in part and denied in part 
Revitalyte’s motion.  (Doc. No. 91.)  Revitalyte now objects to the Magistrate Judge’s 
order as to the interrogatories which were not compelled:  Interrogatory Nos. 1, 3, 4, 6, 7, 
and 20.  (Doc. No. 93.)                                                   
                          DISCUSSION                                     

    The Court must modify or set aside any portion of the Magistrate Judge’s order 
found to be clearly erroneous or contrary to law.  See 
28 U.S.C. § 636
(b)(1)(A); Fed. R. 
Civ. P. 72(a); Local Rule 72.2(a).  This is an “extremely deferential” standard.  Reko v. 
Creative Promotions, Inc., 
70 F. Supp. 2d 1005, 1007
 (D. Minn. 1999).  “A finding is 
‘clearly erroneous’ when although there is evidence to support it, the reviewing court on 

the entire evidence is left with the definite and firm conviction that a mistake has been 
committed.”  Chase v. Comm’r of Internal Revenue, 
926 F.2d 737, 740
 (8th Cir. 1991) 
(quoting United States v. U.S. Gypsum Co., 
333 U.S. 364, 395
 (1948)).  “A magistrate 
judge’s ruling is contrary to law when it either fails to apply or misapplies pertinent 
statutes, case law or rules of procedure.”  Coons v. BNSF Ry. Co., 
268 F. Supp. 3d 983, 991
 (D. Minn. 2017) (citing Edeh v. Midland Credit Mgmt., Inc., 
748 F. Supp. 2d 1030, 1043
 (D. Minn. 2010)).                                                    
I.   Interrogatory No. 1                                                  
    Interrogatory No. 1 asked Abbott to “[i]dentify each element of the Pedialyte 
Trade Dress.”  (Hallerman Decl. Ex. A at 7.)  The Magistrate Judge acknowledged 

Revitalyte’s right to know the elements of the trade dress and ordered Abbott to serve an 
amended response that eliminated terms that left open the possibility of unnamed 
elements.  (Hr’g Tr. 8:12-19, 9:22-25.)  Revitalyte contends that the amended response 
still fails to meet the necessary level of specificity.  (Doc. No. 93 at 2-4.) 
    Revitalyte argues that the trade dress is not sufficiently specific in its claims of 

“bright colors,” “size and alignment,” and “appearance.”  (Doc. No. 93 at 5-6.)  The 
Court need not dive into each of the elements of the alleged trade dress and analyze each 
individually.  The Court has explained that the “total image of a product, the overall 
impression created, not the individual features” is what matters for a trade dress.  
Goddard, Inc. v. Henry’s Foods, Inc., 
291 F. Supp. 2d 1021, 1040, 1044
 (D. Minn. 2003) 

(citing Children’s Factory, Inc. v. Benee’s Toys, Inc., 
160 F.3d 489, 494
 (8th Cir. 1998)).  
The Court has already determined that Abbott has plausibly pled a claim of trade dress 
infringement based on the pleadings.  (Doc. No. 67 at  1 (denying Revitalyte’s motion for 
judgment on the pleadings).)                                              
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 

denial of Revitalyte’s motion to compel a supplemented response to Interrogatory No. 1 
is affirmed and Revitalyte’s objection is overruled.                      
II.  Interrogatory Nos. 3 and 4                                           
    Interrogatory No. 3 asked Abbott, for each element claimed as an embodiment of 
the Pedialyte patent, to “state whether Abbott contends that element affects the cost or 

quality of the Pedialyte Products.”  (Hallerman Decl. Ex. A at 8.)  For each element that 
Abbott did not contend impact on the cost or quality, Interrogatory No. 4 asked Abbott to 
“describe in detail all facts which Abbott relies upon to support that contention.”  (Id.)  
The Magistrate Judge compelled Abbott to answer how the trade dress as a whole 
affected the cost or quality but denied Revitalyte’s motion to compel as to the impact of 

each individual element.  (Hr’g Tr. 15:20-24.)  Revitalyte objects, arguing that because 
each element contributes to the functionality of the trade dress the impact on cost or 
quality should likewise be broken down by element.  (Doc. No. 93 at 9.)   
    Both Revitalyte and Abbott correctly identify that the ultimate decision in trade 
dress functionality is based on the trade dress as a whole.  (Id.; Doc. No. 96 at 9; see 

Pocket Plus, LLC v. Pike Brands, LLC, 
53 F.4th 425, 433
 (8th Cir. 2022).)  Revitalyte 
argues that while the decision is based upon the whole, the analysis looks at each element 
individually, citing an Eighth Circuit case which assessed each element of a trade dress.  
(Doc. No. 93 at 9 (citing Pocket Plus, 
53 F.4th at 433-34
).)  While the court in Pocket 
Plus did analyze certain elements’ impact on quality, the court did not hold that you must 

do so.  See Pocket Plus, 
53 F.4th at 433-35
.                              
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 
denial of Revitalyte’s motion to compel a supplemented response to Interrogatory Nos. 3 
and 4 is affirmed and Revitalyte’s objection is overruled.                
III.  Interrogatory Nos. 6 and 7                                          
    Interrogatory No. 6 asked Abbott to “[i]dentify (i) every person in the United 
States that has manufactured, advertised, or sold an oral electrolyte solution product that 

has used ‘Compare to Pedialyte’ or similar phrase on the label, container, or packaging of 
the product, (ii) the date that Abbott first became aware of any such manufacturing, 
advertising, or sale, and (iii) describe in detail all communications that Abbott had with 
that person or that person’s counsel concerning the use of ‘Compare to Pedialyte’ or any 
other aspect of that label, container, or packaging, including its shape or design.”  

(Hallerman Decl. Ex. A at 8-9.)  Interrogatory No. 7 asked essentially the same for 
“every person in the United States that has manufactured, advertised, or sold an oral 
electrolyte solution product in a bottle or container that is similar in shape and design to 
the bottle claimed as an element of the Pedialyte Trade Dress.”  (Id. at 9.)  The Magistrate 
Judge granted the motion to compel as to subpart (i) of the requests but denied as to 

subparts (ii) and (iii), reasoning that the latter two subparts would be covered by business 
records provided pursuant to Rule 33(d).  (Hr’g Tr. 18:16-19:2.)  Revitalyte objects to the 
ruling insofar as Abbott is not required to provide oral communications.  (Doc. No. 93 
at 11-12.)                                                                
    The Court agrees that oral communications relevant to these interrogatory requests 

must be provided.  Parties invoking Rule 33(d) have a duty to specifically identify every 
document on which they rely for their response.  E.g., Speed RMG Partners, LLC v. 
Arctic Cat Sales Inc., No. 20-cv-609, 
2021 WL 5087362
, at *6 (D. Minn. Jan. 5, 2021).  
The District of Minnesota has extended that duty to require identification of all oral 
communications not identified in documents.  E.g., Marco Techs., LLC v. Midkiff, 
No. 19-cv-2323, 
2020 WL 12442103
, at *15-16 (D. Minn. Oct. 8, 2020).  By denying 
Revitalyte’s motion to compel with regard to subparts (ii) and (iii) of Interrogatory Nos. 6 

and 7, the Magistrate Judge limited Revitalyte’s right to discoverable information.  
    When faced with a similar issue in Ecolab, Inc. v. IBA, Inc., the Court ordered 
IBA, Inc. (“IBA”) to provide information on oral communications.  No. 22-cv-479, 
2024 WL 2382548
, at *7 (D. Minn. March 12, 2024).  There, Ecolab, Inc.’s (“Ecolab”) 
Interrogatory No. 6 asked IBA to “[d]scribe each communication” relevant to the dispute 

and “identify[] the date of each such communication and the party to or from whom each 
such communication was made or received.”  Declaration of Paige Stradley at 10, 
Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  In its response, IBA invoked Rule 33(d).  
Id. at 6
; IBA’s Brief Opposing Ecolab’s Motion to Compel at 27-28, Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  Ecolab then moved to compel a supplemental 

answer, arguing that the answer was insufficient because business records would fail to 
identify oral communications that would be relevant.  Memorandum of Law in Support of 
Plaintiffs’ Motion to Compel at 32, Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  In this 
scenario, Magistrate Judge Schultz found that argument persuasive and ordered IBA to 
“provide the requested information concerning oral contracts and communications.”  

Ecolab, 
2024 WL 2382548
, at *7.  While there are some factual distinctions between the 
case at hand and Ecolab, the Court fails to see how those distinctions would change the 
outcome.                                                                  
    The Court respectfully finds the Magistrate Judge’s denial of Revitalyte’s motion 
to compel as to Interrogatory Nos. 6 and 7 to be clearly erroneous and contrary to law.  
Revitalyte’s objections to this denial are sustained.  Abbott is ordered to supplement the 

responses to Interrogatory Nos. 6 and 7 with information not otherwise captured by the 
documents produced to Revitalyte.                                         
IV.  Interrogatory No. 20                                                 
    Interrogatory No. 20 asked Abbott to, “[o]n a monthly basis from 2013 until 
present and for each Pedialyte Product (separately by Universal Product Code) sold, state 

the number of units Abbott sold, the revenues Abbott received, the gross profits earned, 
and the net profits earned in U.S. Commerce.”  (Hallerman Decl. Ex. A at 11-12.)  Abbott 
agreed to “produce nonprivileged documents sufficient to show the retail unit sales of the 
Pedialyte Product in the United States since 2013.”  (Hallerman Decl. Ex. B at 39.)  The 
Magistrate Judge denied the motion to compel, reasoning that total unit sales would be 

sufficient for Revitalyte to defend the claim and that revenue and unit sales breakdowns 
per product were unnecessary because Abbott is no longer seeking monetary damages.  
(Hr’g Tr. 25:2-7.)                                                        
    Revitalyte objects, arguing that per-unit information is necessary because each 
Pedialyte product has a distinct trade dress.  (Doc. No. 93 at 13.)  Abbott is not claiming 

separate trade dresses for each product.  (Id.)  In fact, Abbott’s trade dress claims are for 
the entirety of the Pedialyte brand, not each product line.  (See Am. Compl. ¶ 3.)  
Revitalyte also cites an Eighth Circuit case for the proposition that commercial success is 
considered when determining trade dress functionality.  (Doc. No. 93 at 13 (citing 
Aromatique, Inc. v. Gold Seal, Inc., 
28 F.3d 863
 (8th Cir. 1994)).)  The Court fails to see 
how that necessitates Revitalyte’s access to per-product sales and revenue.  Revitalyte is 
getting information on Abbott’s commercial success through its access to total unit sales.  

The Court agrees with the Magistrate Judge that total unit sales are sufficient for 
Revitalyte’s purposes.                                                    
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 
denial of Revitalyte’s motion to compel a supplemented response to Interrogatory No. 20 
is affirmed and Revitalyte’s objection is overruled.                      

                         CONCLUSION                                      
    For the reasons outlined above, the Court sustains in part and overrules in part 
Revitalyte’s objections.  Revitalyte’s objections as to Interrogatory Nos. 6 and 7 are 
sustained.  Revitalyte’s objections as to Interrogatory Nos. 1, 3, 4, and 20 are overruled.  
Accordingly, the Magistrate Judge’s order is affirmed in part and respectfully modified in 

part.                                                                     

ORDER

    Based upon the files, records, and proceedings herein, and for the reasons stated 
above, IT IS HEREBY ORDERED that:                                         
    1.   Defendant Revitalyte LLC’s objections (Doc. No. [93]) to Magistrate Judge 

David T. Schultz’s order dated October 23, 2024, are SUSTAINED IN PART and 
OVERRULED IN PART.                                                        
         a.   Defendant Revitalyte LLC’s objections to Magistrate Judge David T. 
    Schultz’s order dated October 23, 2024, regarding Interrogatory Nos. 6 and 7 are 
    SUSTAINED.                                                           

         b.   Defendant Revitalyte LLC’s objections to Magistrate Judge David T. 
    Schultz’s order dated October 23, 2024, regarding Interrogatory Nos. 1, 3, 4, 
    and 20 are OVERRULED.                                                
    2.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, (Doc. 
No. [91]) is AFFIRMED IN PART and MODIFIED IN PART.                       

         a.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, 
    is AFFIRMED as to Interrogatory Nos. 1, 3, 4, and 20.                
         b.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, 
    is respectfully MODIFIED as to Interrogatory Nos. 6 and 7.           

Dated:  December 4, 2024      s/Donovan W. Frank                          
                             DONOVAN W. FRANK                            
                             United States District Judge                

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Abbott Laboratories,                    Civil No. 23-1449 (DWF/DTS)      

               Plaintiff,                                                

v.                                               MEMORANDUM              
                                            OPINION AND ORDER            
Revitalyte LLC,                                                          

               Defendant.                                                


                        INTRODUCTION                                     
    This matter is before the Court on Defendant Revitalyte LLC’s (“Revitalyte”) 
objections (Doc. No. 93) to Magistrate Judge David T. Schultz’s order on October 23, 
2024 (Doc. No. 91 (articulated in Doc. No. 92 (“Hr’g Tr.”))).  Plaintiff Abbott 
Laboratories (“Abbott”) filed a response.  (Doc. No. 96.)  For the reasons set forth below, 
the Court sustains in part and overrules in part Revitalyte’s objections.  Accordingly, the 
Magistrate Judge’s order is affirmed in part and respectfully modified in part. 
                         BACKGROUND                                      
    Abbott brings state law and federal law claims of trade dress infringement, 
trademark infringement, unfair competition, false designation of origin, false advertising, 
and trademark and trade dress dilution by tarnishment against Revitalyte.  (Doc. No. 22 
(“Am. Compl.”) ¶¶ 170-203.)  Revitalyte served twenty-three interrogatories and sixty-
two requests for production on Abbott.  (Doc. No. 73 (“Hallerman Decl.”) Ex. A at 7-12; 
id. Ex. C at 48-59.)  Abbott objected to each of these requests for a litany of reasons and 
refused to respond to six interrogatories and thirty requests for production.  (Hallerman 
Decl. Exs. B, D.)  Revitalyte moved to compel Abbott to respond fully to nine 
interrogatories and twenty requests for production.  (Doc. No. 72.)  Abbott opposed each.  

(Doc. No. 85.)  Magistrate Judge David T. Schultz granted in part and denied in part 
Revitalyte’s motion.  (Doc. No. 91.)  Revitalyte now objects to the Magistrate Judge’s 
order as to the interrogatories which were not compelled:  Interrogatory Nos. 1, 3, 4, 6, 7, 
and 20.  (Doc. No. 93.)                                                   
                          DISCUSSION                                     

    The Court must modify or set aside any portion of the Magistrate Judge’s order 
found to be clearly erroneous or contrary to law.  See 
28 U.S.C. § 636
(b)(1)(A); Fed. R. 
Civ. P. 72(a); Local Rule 72.2(a).  This is an “extremely deferential” standard.  Reko v. 
Creative Promotions, Inc., 
70 F. Supp. 2d 1005, 1007
 (D. Minn. 1999).  “A finding is 
‘clearly erroneous’ when although there is evidence to support it, the reviewing court on 

the entire evidence is left with the definite and firm conviction that a mistake has been 
committed.”  Chase v. Comm’r of Internal Revenue, 
926 F.2d 737, 740
 (8th Cir. 1991) 
(quoting United States v. U.S. Gypsum Co., 
333 U.S. 364, 395
 (1948)).  “A magistrate 
judge’s ruling is contrary to law when it either fails to apply or misapplies pertinent 
statutes, case law or rules of procedure.”  Coons v. BNSF Ry. Co., 
268 F. Supp. 3d 983, 991
 (D. Minn. 2017) (citing Edeh v. Midland Credit Mgmt., Inc., 
748 F. Supp. 2d 1030, 1043
 (D. Minn. 2010)).                                                    
I.   Interrogatory No. 1                                                  
    Interrogatory No. 1 asked Abbott to “[i]dentify each element of the Pedialyte 
Trade Dress.”  (Hallerman Decl. Ex. A at 7.)  The Magistrate Judge acknowledged 

Revitalyte’s right to know the elements of the trade dress and ordered Abbott to serve an 
amended response that eliminated terms that left open the possibility of unnamed 
elements.  (Hr’g Tr. 8:12-19, 9:22-25.)  Revitalyte contends that the amended response 
still fails to meet the necessary level of specificity.  (Doc. No. 93 at 2-4.) 
    Revitalyte argues that the trade dress is not sufficiently specific in its claims of 

“bright colors,” “size and alignment,” and “appearance.”  (Doc. No. 93 at 5-6.)  The 
Court need not dive into each of the elements of the alleged trade dress and analyze each 
individually.  The Court has explained that the “total image of a product, the overall 
impression created, not the individual features” is what matters for a trade dress.  
Goddard, Inc. v. Henry’s Foods, Inc., 
291 F. Supp. 2d 1021, 1040, 1044
 (D. Minn. 2003) 

(citing Children’s Factory, Inc. v. Benee’s Toys, Inc., 
160 F.3d 489, 494
 (8th Cir. 1998)).  
The Court has already determined that Abbott has plausibly pled a claim of trade dress 
infringement based on the pleadings.  (Doc. No. 67 at  1 (denying Revitalyte’s motion for 
judgment on the pleadings).)                                              
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 

denial of Revitalyte’s motion to compel a supplemented response to Interrogatory No. 1 
is affirmed and Revitalyte’s objection is overruled.                      
II.  Interrogatory Nos. 3 and 4                                           
    Interrogatory No. 3 asked Abbott, for each element claimed as an embodiment of 
the Pedialyte patent, to “state whether Abbott contends that element affects the cost or 

quality of the Pedialyte Products.”  (Hallerman Decl. Ex. A at 8.)  For each element that 
Abbott did not contend impact on the cost or quality, Interrogatory No. 4 asked Abbott to 
“describe in detail all facts which Abbott relies upon to support that contention.”  (Id.)  
The Magistrate Judge compelled Abbott to answer how the trade dress as a whole 
affected the cost or quality but denied Revitalyte’s motion to compel as to the impact of 

each individual element.  (Hr’g Tr. 15:20-24.)  Revitalyte objects, arguing that because 
each element contributes to the functionality of the trade dress the impact on cost or 
quality should likewise be broken down by element.  (Doc. No. 93 at 9.)   
    Both Revitalyte and Abbott correctly identify that the ultimate decision in trade 
dress functionality is based on the trade dress as a whole.  (Id.; Doc. No. 96 at 9; see 

Pocket Plus, LLC v. Pike Brands, LLC, 
53 F.4th 425, 433
 (8th Cir. 2022).)  Revitalyte 
argues that while the decision is based upon the whole, the analysis looks at each element 
individually, citing an Eighth Circuit case which assessed each element of a trade dress.  
(Doc. No. 93 at 9 (citing Pocket Plus, 
53 F.4th at 433-34
).)  While the court in Pocket 
Plus did analyze certain elements’ impact on quality, the court did not hold that you must 

do so.  See Pocket Plus, 
53 F.4th at 433-35
.                              
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 
denial of Revitalyte’s motion to compel a supplemented response to Interrogatory Nos. 3 
and 4 is affirmed and Revitalyte’s objection is overruled.                
III.  Interrogatory Nos. 6 and 7                                          
    Interrogatory No. 6 asked Abbott to “[i]dentify (i) every person in the United 
States that has manufactured, advertised, or sold an oral electrolyte solution product that 

has used ‘Compare to Pedialyte’ or similar phrase on the label, container, or packaging of 
the product, (ii) the date that Abbott first became aware of any such manufacturing, 
advertising, or sale, and (iii) describe in detail all communications that Abbott had with 
that person or that person’s counsel concerning the use of ‘Compare to Pedialyte’ or any 
other aspect of that label, container, or packaging, including its shape or design.”  

(Hallerman Decl. Ex. A at 8-9.)  Interrogatory No. 7 asked essentially the same for 
“every person in the United States that has manufactured, advertised, or sold an oral 
electrolyte solution product in a bottle or container that is similar in shape and design to 
the bottle claimed as an element of the Pedialyte Trade Dress.”  (Id. at 9.)  The Magistrate 
Judge granted the motion to compel as to subpart (i) of the requests but denied as to 

subparts (ii) and (iii), reasoning that the latter two subparts would be covered by business 
records provided pursuant to Rule 33(d).  (Hr’g Tr. 18:16-19:2.)  Revitalyte objects to the 
ruling insofar as Abbott is not required to provide oral communications.  (Doc. No. 93 
at 11-12.)                                                                
    The Court agrees that oral communications relevant to these interrogatory requests 

must be provided.  Parties invoking Rule 33(d) have a duty to specifically identify every 
document on which they rely for their response.  E.g., Speed RMG Partners, LLC v. 
Arctic Cat Sales Inc., No. 20-cv-609, 
2021 WL 5087362
, at *6 (D. Minn. Jan. 5, 2021).  
The District of Minnesota has extended that duty to require identification of all oral 
communications not identified in documents.  E.g., Marco Techs., LLC v. Midkiff, 
No. 19-cv-2323, 
2020 WL 12442103
, at *15-16 (D. Minn. Oct. 8, 2020).  By denying 
Revitalyte’s motion to compel with regard to subparts (ii) and (iii) of Interrogatory Nos. 6 

and 7, the Magistrate Judge limited Revitalyte’s right to discoverable information.  
    When faced with a similar issue in Ecolab, Inc. v. IBA, Inc., the Court ordered 
IBA, Inc. (“IBA”) to provide information on oral communications.  No. 22-cv-479, 
2024 WL 2382548
, at *7 (D. Minn. March 12, 2024).  There, Ecolab, Inc.’s (“Ecolab”) 
Interrogatory No. 6 asked IBA to “[d]scribe each communication” relevant to the dispute 

and “identify[] the date of each such communication and the party to or from whom each 
such communication was made or received.”  Declaration of Paige Stradley at 10, 
Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  In its response, IBA invoked Rule 33(d).  
Id. at 6
; IBA’s Brief Opposing Ecolab’s Motion to Compel at 27-28, Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  Ecolab then moved to compel a supplemental 

answer, arguing that the answer was insufficient because business records would fail to 
identify oral communications that would be relevant.  Memorandum of Law in Support of 
Plaintiffs’ Motion to Compel at 32, Ecolab, 
2024 WL 2382548
 (No. 22-cv-479).  In this 
scenario, Magistrate Judge Schultz found that argument persuasive and ordered IBA to 
“provide the requested information concerning oral contracts and communications.”  

Ecolab, 
2024 WL 2382548
, at *7.  While there are some factual distinctions between the 
case at hand and Ecolab, the Court fails to see how those distinctions would change the 
outcome.                                                                  
    The Court respectfully finds the Magistrate Judge’s denial of Revitalyte’s motion 
to compel as to Interrogatory Nos. 6 and 7 to be clearly erroneous and contrary to law.  
Revitalyte’s objections to this denial are sustained.  Abbott is ordered to supplement the 

responses to Interrogatory Nos. 6 and 7 with information not otherwise captured by the 
documents produced to Revitalyte.                                         
IV.  Interrogatory No. 20                                                 
    Interrogatory No. 20 asked Abbott to, “[o]n a monthly basis from 2013 until 
present and for each Pedialyte Product (separately by Universal Product Code) sold, state 

the number of units Abbott sold, the revenues Abbott received, the gross profits earned, 
and the net profits earned in U.S. Commerce.”  (Hallerman Decl. Ex. A at 11-12.)  Abbott 
agreed to “produce nonprivileged documents sufficient to show the retail unit sales of the 
Pedialyte Product in the United States since 2013.”  (Hallerman Decl. Ex. B at 39.)  The 
Magistrate Judge denied the motion to compel, reasoning that total unit sales would be 

sufficient for Revitalyte to defend the claim and that revenue and unit sales breakdowns 
per product were unnecessary because Abbott is no longer seeking monetary damages.  
(Hr’g Tr. 25:2-7.)                                                        
    Revitalyte objects, arguing that per-unit information is necessary because each 
Pedialyte product has a distinct trade dress.  (Doc. No. 93 at 13.)  Abbott is not claiming 

separate trade dresses for each product.  (Id.)  In fact, Abbott’s trade dress claims are for 
the entirety of the Pedialyte brand, not each product line.  (See Am. Compl. ¶ 3.)  
Revitalyte also cites an Eighth Circuit case for the proposition that commercial success is 
considered when determining trade dress functionality.  (Doc. No. 93 at 13 (citing 
Aromatique, Inc. v. Gold Seal, Inc., 
28 F.3d 863
 (8th Cir. 1994)).)  The Court fails to see 
how that necessitates Revitalyte’s access to per-product sales and revenue.  Revitalyte is 
getting information on Abbott’s commercial success through its access to total unit sales.  

The Court agrees with the Magistrate Judge that total unit sales are sufficient for 
Revitalyte’s purposes.                                                    
    The Magistrate Judge’s ruling was not clearly erroneous or contrary to law.  The 
denial of Revitalyte’s motion to compel a supplemented response to Interrogatory No. 20 
is affirmed and Revitalyte’s objection is overruled.                      

                         CONCLUSION                                      
    For the reasons outlined above, the Court sustains in part and overrules in part 
Revitalyte’s objections.  Revitalyte’s objections as to Interrogatory Nos. 6 and 7 are 
sustained.  Revitalyte’s objections as to Interrogatory Nos. 1, 3, 4, and 20 are overruled.  
Accordingly, the Magistrate Judge’s order is affirmed in part and respectfully modified in 

part.                                                                     

ORDER

    Based upon the files, records, and proceedings herein, and for the reasons stated 
above, IT IS HEREBY ORDERED that:                                         
    1.   Defendant Revitalyte LLC’s objections (Doc. No. [93]) to Magistrate Judge 

David T. Schultz’s order dated October 23, 2024, are SUSTAINED IN PART and 
OVERRULED IN PART.                                                        
         a.   Defendant Revitalyte LLC’s objections to Magistrate Judge David T. 
    Schultz’s order dated October 23, 2024, regarding Interrogatory Nos. 6 and 7 are 
    SUSTAINED.                                                           

         b.   Defendant Revitalyte LLC’s objections to Magistrate Judge David T. 
    Schultz’s order dated October 23, 2024, regarding Interrogatory Nos. 1, 3, 4, 
    and 20 are OVERRULED.                                                
    2.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, (Doc. 
No. [91]) is AFFIRMED IN PART and MODIFIED IN PART.                       

         a.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, 
    is AFFIRMED as to Interrogatory Nos. 1, 3, 4, and 20.                
         b.   Magistrate Judge David T. Schultz’s order dated October 23, 2024, 
    is respectfully MODIFIED as to Interrogatory Nos. 6 and 7.           

Dated:  December 4, 2024      s/Donovan W. Frank                          
                             DONOVAN W. FRANK                            
                             United States District Judge                

Reference

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