In Apple, Inc. v. Samsung Electronics Co., No. 12-0630 (N.D. Cal. May 9, 2013), the court ordered Google, a third party recipient of a subpoena, to reveal the search terms and custodians it used to produce documents under Fed. R. Civ. P. 45. The court rejected Google’s argument that “its status as a third party to the litigation exempts it from obligations parties may incur to show the sufficiency of their production, at least absent a showing by [the party issuing the subpoena] that its production is deficient.” The court held that “transparency and collaboration is essential to meaningful, cost-effective discovery” and that Google could not “stand outside of these tenets because of its third party [sic] status.” The court also noted that Google had “abandoned” an argument that its search methodology was protected as work product, “no doubt in part because case law suggests otherwise.”