A federal judge in Washington, D.C., split a discovery dispute between Equifax and nonparty medical-debt collector Revco Solutions on October 28. Judge Trevor McFadden quashed a narrowed request for records showing how effectively Revco collects debts, finding the burden disproportionate. He granted Equifax’s motion to compel a separate request for account-level data after rejecting Revco’s objections on the record presented. Revco Solutions Inc. v. Equifax Inc.
The burden depended on how the records were organized
The subpoena arose from a California lawsuit challenging credit-reporting agencies’ medical-debt reporting policies. Equifax sought Revco’s records for class certification and its merits defense. The D.C. court found the effectiveness information relevant, but credited declarations explaining that it was dispersed across more than one million reporting instances, without a queryable field that could identify the responsive subset. Revco estimated thousands of reviewer hours and hundreds of thousands of dollars in costs. Revco Solutions Inc. v. Equifax Inc.
Equifax argued that the claimed search difficulty was implausible given modern e-discovery practices. The court found no legal or factual basis in that argument to disbelieve Revco’s declarations. Its proportionality analysis also considered Revco’s nonparty status, the comparatively limited importance of the requested market information, other potential sources, and three reports Revco had already agreed to provide. A general offer of reasonable cost shifting did not resolve the burden. Revco Solutions Inc. v. Equifax Inc.
The privacy objection had a different outcome
The separate request sought data about medical-debt accounts. Equifax had narrowed it to a sample of 10,000 records and offered measures including redaction or de-identification and an outside-counsel-only designation under the existing protective order. The court found Revco’s account of contractual notice obligations too vague and held that its state-law argument was forfeited because it appeared only in reply; Revco also had not identified a particular state law. The court therefore declined to quash Request Seven and granted the cross-motion to compel it. Revco Solutions Inc. v. Equifax Inc.
Analysis: describe the work, not just the data volume
Analysis. The two outcomes illustrate the difference between a concrete account of discovery burden and a general objection. Revco explained the reporting structure, manual work, staffing costs and operational impact supporting one request. Its privacy argument lacked comparable detail, and Equifax offered protective measures. For e-discovery reporting, the lesson is evidentiary: searchability and proportionality turn on the actual records and requested task. This decision does not establish that large collections are automatically exempt from discovery or that health-data protections can be disregarded. Revco Solutions Inc. v. Equifax Inc.
Status and source limits
This is a district-court discovery ruling, not a decision on the California lawsuit’s merits or a nationwide exemption from subpoena compliance. The report is based on the complete ten-page memorandum order. The parties’ declarations, underlying discovery and account data were not independently inspected. The saved October 28 CourtListener history checks are limited to its available index and docket records; they cannot establish that no later filing, correction or review exists elsewhere. Revco Solutions Inc. v. Equifax Inc.
Sources
Revco Solutions Inc. v. Equifax Inc.. District Court, District of Columbia. 1:26-mc-00138 (TNM). Filed 2026-10-28. Published.
AI-assisted reporting based on court records retrieved through CourtListener. This analysis is produced by eDiscovery Decoder; it is not reviewed or endorsed by Free Law Project.