In the private litigation challenging the NSA’s policy of spying on Americans, U.S. District Judge Vaughn Walker in the Northern District of California issued an interim order defining preservation as “taking reasonable steps to prevent the partial or full destruction, alteration, testing, deletion, shredding, incineration, wiping, relocation, migration, theft, or mutation of such material, as well as negligent or intentional handling that would make material incomplete or inaccessible” and directing counsel “to inquire of their respective clients if the business practices of any party involve the routine destruction, recycling, relocation, or mutation of such materials and, if so, direct the party, to the extent practicable for the pendency of this order, either to (1) halt such business processes; (2) sequester or remove such material from the business process; or (3) arrange for the preservation of complete and accurate duplicates or copies of such material, suitable for later discovery if requested.” See In re NSA Telecommunications Records Litigation, No.06-1791, 2007 WL 3306579 (N.D.Cal. Nov. 6, 2007).