If mobile device collection is rare for your company, it may become less so. Adversaries are seeking mobile data with increasing frequency, including in government investigations and non-party subpoenas. A recent example is the $200 million fine levied against J.P. Morgan by U.S. financial regulators for the company's failure to preserve certain business-related communications on its employees' personal devices. Consider another recent case, Sandoz Inc. et al. v. United Therapeutics Corporation, in which the court ordered the defendant to turn over certain text messages from its chief financial officer's personal cell phone.