Discovery overbreadth and the resulting excessive litigation costs are particularly common in multidistrict and other complex litigation. The Texas Supreme Court addressed this problem with respect to cell phone data in In re Kuraray America, Inc., — S.W.3d —, 2022 WL 17542911 (Tex. Dec. 9, 2022). The court held that discovery of cell phone data must be limited to information that the requesting party demonstrates is relevant to the case.