In Peerless Industries, Inc. v. Crimson AV, LLC, No. 11-cv-1768 (N.D. Ill. Jan. 8, 2013), the Northern District of Illinois granted a sanctions motion related to defendant’s failure to ensure that an affiliated company made an adequate response to document requests. One of the defendant’s witnesses testified at deposition that documents had been collected from the affiliated company according to a process outlined “I guess by the [e-discovery] vendor.” The court found that the defendant “took a back seat approach and instead let the [e-discovery] process proceed through a vendor.” The court held that the defendants thus “had no part in the process of obtaining the requested discovery or of determining how the [affiliated party] managed their documents and what might be relevant to plaintiff’s requests.” The court concluded that “[s]uch a hands-off approach is insufficient,” and ordered the defendants to “show that they in fact searched for the requested documents” and to verify the results of that search.