In PersonalWeb Technologies, LLC v. Google Inc., No. C13-01317 (N.D. Cal. Aug. 19, 2014), the district court denied the plaintiff’s request for an order compelling the defendant to produce its document retention policies and the litigation hold notices issued in the case. The court reasoned the request was made too late – over a year and a half after the plaintiff’s interrogatories originally requesting the information were made, and well after the fact-discovery cutoff date. The district court also found that the plaintiff’s failure to explain the eighteen-month gap, coupled with the court’s recent finding that the plaintiff committed spoliation by failing to institute its own litigation hold, suggested that the plaintiff was merely trying to retaliate against the defendant with its request. The court also held that the litigation hold notice itself was protected attorney-client communications and/or work product.