In Southern U.S. Trade Association v. Guddh, No. 13-31086 (5th Cir. Apr. 22, 2014), plaintiff, a nonprofit company, brought a defamation suit alleging that defendant had made offensive and actionable comments about plaintiff on several websites. In discovery, defendant was sanctioned for failing to respond to discovery requests, and then subsequently failed to appear for an in-person deposition, as ordered by the court. The court also ordered defendant to appear in person at a scheduled pre-trial conference, and warned that his failure to do so could result in further sanctions, including dismissal of the suit. When defendant nonetheless failed to appear, the court sanctioned defendant by striking all of his pleadings and awarding summary judgment in favor of plaintiff for the full amount of damages claimed. On appeal, the Fifth Circuit affirmed, holding that the district court did not abuse its discretion in imposing the sanctions. The court reasoned that, although the striking of all pleadings is a serious sanction, defendant’s repeated conduct in the face of lesser sanctions, coupled with the court’s explicit warning of severe sanctions, provided sufficient factual basis for the ruling.