The Standard for In Camera Review

“The standard for in camera review is not high, but it’s not nothing either, and the Court doesn’t think it’s been met here.”  BSD Crown, LTD v. Amazon.Com, Inc., 2026 WL 2644130 (N.D. Cal. Sep. 8, 2026).  Given the roles of the communicating individuals, “there is nothing suspicious about these work product claims.”

BSD Crown demonstrates that a request for in camera review—like every other discovery motion—should be supported by a detailed factual predicate.

For additional information on requests for in camera review, please see:

• The Standard for In Camera Review of Assertedly Privileged Documents (Jul. 9, 2024)
• Order Granting In Camera Review of Work Product Claim (Apr. 14, 2025)