Title Capital Mgt. v. Progress Residential (S.D. Fla., 2017)
Key Insight: The onset of the duty under Rule 37(e) does not have to say which exact kind of litigation that will occur. Prejudice was not found, but the question of intent was pushed to later.
Nature of Case: Contract, copyright
Electronic Data Involved: records, documents, and logs of the company
Keywords: Spoliation, intent to deprive, sanctions, prejudice