In Leach Farms, Inc. v. Ryder Integrated Logistics, Inc., No. 14-C-0001, 2015 WL 348238 (E.D. Wis. Jan. 26, 2015), the court rejected plaintiff’s request for discovery sanctions based upon defendant’s insistence on an allegedly overbroad electronic search. Defendant demanded that plaintiff use broad search terms to locate electronic documents for production. Plaintiff objected on the grounds that the broad terms would “generate thousands of irrelevant and duplicative documents,” but eventually agreed to run the broad terms while reserving its objection. Approximately 16,000 documents “hit” on the search terms and plaintiff made those documents available to defendant via an electronic database. After defendant then reviewed those documents using additional search terms and other methods, plaintiff’s counsel “went back in[to] [the database] and took a peek at the results” of defendant’s review, revealing that defendant “had opened only 4,107 of the 16,102 documents,” and moved for sanctions, arguing that “if [defendant’s] lawyers were able to use search terms to winnow their search of the documents down to only 25% of those produced, they should have agreed to allow [plaintiff] to use those same terms when making its expanded production.” The court rejected this argument, crediting defendant’s argument that it properly used “multiple, evolving searches” to review the broader production, which would not have been practicable until the broader universe of documents was gathered.