A U.S. Magistrate sitting in the District of Columbia revisited an ongoing e-discovery dispute. After noting that even under the old rules a producing party had the obligation to search available electronic systems for the information requested, the court then commented that “under the new pertinent rule, the producing party is relieved of producing specifically identified inaccessible data only upon a showing of undue burden or cost. Even then, the court may order discovery of the data identified as inaccessible ‘if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C),’ i.e., the rule that balances the costs of the discovery demanded against its benefits. The obvious negative corollary of this rule” the court continued, “is that accessible data must be produced at the cost of the producing party; cost-shifting does not even become a possibility unless there is first a showing of inaccessibility. Thus, it cannot be argued that a party should ever be relieved of its obligation to produce accessible data merely because it may take time and effort to find what is necessary.”See Peskoff v. Faber, No. 04-526, 2007 WL 530096 (D.D.C. Feb. 21, 2007), [and, later proceeding, 2007 WL 2416119 (D.D.C. Aug. 27, 2007).]