In the well-publicized case In re Google Play Store Antitrust Litigation (N.D. Cal. March 28, 2023) California District Judge James Donato ruled for sanctions against Google for Google Chat spoliation. There are plenty of ediscovery lessons to take away from this case, particularly given that Google is, in the judge’s words, “a frequent and sophisticated litigation party.” So how did something as fundamental as data spoliation come about?