In a copyright infringement action filed by the Motion Picture Association of America (MPAA) against the owners and operators of TorrentSpy on the basis that the website promotes and enables piracy, the plaintiffs sought production of the IP addresses of users, the users’ requests for dot-torrent files, and the dates and times of such requests. The defendants argued that such Server Log Data, which is stored in the server’s Random Access Memory (“RAM”) for a period of about six hours for processing purposes, does not constitute “electronically stored information” under the Rules because the data is never fixed on the website or in any media from which it can be reviewed or examined in any tangible form. Magistrate Judge Chooljian, sitting in the Central District of California, rejected this argument, pointing to several cases describing RAM as “temporary storage” and concluding that the data “is transmitted through and temporarily stored in RAM while the requests of defendants’ website users for dot-torrent files are processed.” While declining to sanction defendants for spoliation, the court entered a preservation order requiring the defendants to create and maintain a log of the Server Log Data, and concluded, further, that defendants had failed to establish that such data was not “reasonably accessible” due to undue burden or cost under the amended Rule. Citing privacy concerns, the court ordered that the IP address of TorrentSpy users be masked. See Columbia Pictures v. Bunnelli, No.06-1093 (C.Cal. May 29, 2007). [Affirmed: 245 F.R.D. 443 (D.Cal. 2007).]