Litigants share the burden of addressing proportionality.

proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.

collective Polaris Innovations Ltd. v. Kingston Technologies Co. Id Novanta Corp. v. Iradion Laser Id Discovery requests should be narrowly tailored. Cinclips v. Z Keepers, Cinclips Id Rembrandt Diagnostics v. Innovacon Id. Rembrandt Id. Boilerplate proportionality objections will not suffice. See e.g. Polaris Innovations Ltd. TNA Austl. PTY Ltd. v. PPM Techs. Ecojet v. Luraco Id Ecojet Id. There is no “one-size fits all” approach. Lanard Toys Ltd. v. Dolgencorp Id Phase your e-discovery. after DCG Systems v. Checkpoint Techs. Proportionality may not be the answer. See Conclusion. James J. DeCarlo is a shareholder with Greenberg Traurig, in the Intellectual Property and Technology Practice. Jamie L. Ryerson is an associate with the firm, focusing his practice on intellectual property litigation and counseling . Alyssa Wall is a third-year student at NYU School of Law and a summer associate with the firm.