In Jannx Medical Systems Inc. v. Methodist Hospitals Inc. , a November decision from U.S. Magistrate Judge for the Northern District of Indiana Paul R. Cherry, the plaintiff in the case produced electronically stored information to the defendants in PDF form.

In particular, the plaintiff produced files that pertained to transactions relevant to the litigation, but with no way of associating the files with any given transaction, determining how the reports pertaining to the transaction were generated or tracing any of those reports to the data on which they relied. The defendants complained and the court agreed, ordering the plaintiff to produce the information in a format that was “reasonably usable, i.e., fully searchable and manipulable, with the connections between data fields intact.”

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