Capitol Records, Inc. v. MP3tunes, LLC, 2009 WL 2568431 (S.D.N.Y. Aug. 13, 2009)

Key Insight: Court found emails ?not reasonably accessible? in light of representations of undue burden, including the need for vendor assistance to accomplish the necessary searching, and, upon shifting the burden to defendant to show ?good cause? for the additional emails sought, ordered some specific searching using specific terms and for the parties to confer to identify additional custodians

Nature of Case: Copyright infringement

Electronic Data Involved: Emails, ESI