In Oracle America Inc. v. Google Inc., No. 10-cv-03561 (N.D. Cal. Dec. 3, 2015), the district court granted in part a motion by plaintiff to add 22 e-discovery custodians to the defendant’s document search. The court took both parties to task for failing to “submit a proper analysis of the Rule 26 proportionality factors” in their briefing on the motion. For example, the moving party did not address “the importance of the requested discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” The court therefore “ma[de] its best judgment based on the limited information before it” and ordered the defendant to add 10 e-discovery custodians selected by the plaintiff.