In Boston Scientific Corp. v. Lee, No. 14-mc-80188 (N.D. Cal. Aug. 4, 2014), the plaintiff, Boston Scientific Corp. (“BSC”), sued its former employee for allegedly breaching his confidentially agreement with BSC while working for one of BSC’s direct competitors, Nevro.  BSC served a subpoena on Nevro requesting a complete forensic image of two laptops used by the defendant.  Nevro moved to quash the subpoena, because the second laptop was used by other Nevro employees before the defendant used the laptop, and it contained confidential information and trade secrets.  Although the district court agreed that the computers contained discoverable information, it held that “by demanding nothing less than a complete forensic image of not just one but two laptops belonging to a direct competitor, [BSC] demands too much.”  The court found that compliance with the subpoena would necessarily disclose material protected by Federal Rule of Civil Procedure 45, such as unrelated trade secrets and confidential information, and quashed the subpoena.