| http://www.w3.org/ns/prov#value | - However, many courts in 2012 stuck with the Zubulake standard, such as Voom Holdings LLC v. EchoStar Satellite (News - Alert) LLC, 2012 WL 265833 (N.Y. App. Div. Jan. 31, 2012), in which the court found the defendant's failure to issue a litigation hold and suspend automatic deletion of corporate e-mails before litigation commenced constituted gross negligence and warranted severe sanctions.
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