At the start of the era of e-discovery, electronically stored information (ESI)—a term not even coined at the time—was relatively straightforward. One could perhaps expect to encounter a small set of WordPerfect documents and a PST file or two. Times have changed; today we can expect ESI to be comprised of vast quantities of information from a multitude of communication and office systems. What has not changed—and indeed is now more crucial than ever—is the need for parties and counsel to maintain technological expertise around ESI and the e-discovery process. This was demonstrated in a recent decision from the Southern District of New York, where the defense's adept handling of key evidence they suspected had been fabricated resulted in severe sanctions against the plaintiff and her counsel, including a dismissal with prejudice.