By now, Qualcomm's $8.5 million sanction for failing to produce tens of thousands of documents during discovery--because it didn't search the computers of deponents and witnesses--has become something of a cautionary tale (Qualcomm Inc. v. Broadcom Corp., 2008 WL 66932 (S.D. Cal. Jan. 7, 2008)). If Qualcomm had had a data map--and therefore knew what kind of electronic data it had and where it was...
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