In an ongoing case in federal court in Washington state, Amazon has been waging an effort to cast its opposing party's electronically stored information discovery requests as too heavy to bear. See Garner v. Amazon.com, No. C21-0750RSL, 2022 WL 16553158 (W.D. Wash. Oct. 31, 2022). In its response to a motion to compel, Amazon argued that the plaintiffs' requests were not proportional to the needs of the case and therefore should not require a response. Such arguments have become standard fare since Rule 26(b)(1) was amended in 2015 to emphasize proportionality as a limit to discovery. But in an order late last year, the court rejected those arguments, finding that Amazon, on this occasion, failed to deliver the goods.