Phone limits on the number of stored text messages may aid in a no-spoliation finding. The Pennsylvania Superior Court found in PTSI, Inc. v. Haley, No. 84 WDA 2012 (Pa. Sup. Ct. May 24, 2013), that the trial court did not abuse its discretion by denying PTSI’s motion for sanctions for spoliation of cell phone text messages. The court noted that “[t]he doctrine of spoliation only applies to the improper intentional destruction of evidence that could be relevant to the case.” Here, both defendants routinely deleted text messages, often on a daily basis, so as not to unduly encumber their iPhones. The court found that the volume of text messages and the limited amount of storage on cell phones would have made it very difficult, if not impossible, to save all text messages and to continue to use the phone for messaging. Defendants’ conduct was therefore routine and not motivated by bad faith. In addition, the text messages deleted after entry of the Preservation Order were not relevant to the case because the defendants were no longer employed at the plaintiff company.