Federal Rule of Civil Procedure 37(e) was intended to address some unique challenges surrounding the preservation of electronically stored information (ESI). Since 2015, courts frequently have utilized the rule when deciding motions for sanctions for ESI spoliation. One key question rarely addressed, though, is whether, in addition to the content of ESI, Rule 37(e) also applies to its metadata—the properties and other information about electronic files. In a recent decision, where spoliated metadata would have provided details relevant to a party's claims, a court determined that it does.