In 2005, a Pew Research Center survey revealed approximately 65% of American adults used cellphones and 5% engaged with social media platforms. The following year, Federal Rule of Civil Procedure 34 was amended to address the proliferation of electronically stored information (ESI), defined to include "writings … photographs, sound recordings, images, or other data or data compilations—stored in any medium from which information can be obtained." The committee notes recognized the growth in ESI and explicitly used the example of email as a new type of discoverable communication.