Procter & Gamble Co. v. Haugen, 179 F.R.D. 622 (D. Utah 1998)

Key Insight: Plaintiff sanctioned $10,000 for failing to preserve or search email of certain persons; key word search to be narrowed

Nature of Case: Business sued competitors for defamation and unfair competition

Electronic Data Involved: Email, databases (scope of key word search)