According to the professional opinion of plaintiff’s technical expert, reasonable steps to preserve evidence would have entailed sending the Preservation Letter to all Lilly employees, suspending the routine destruction of such evidence, and “taking steps to preserve active data stored or found on servers, backup tapes, or other media.”  The next step “is collection and review.”  In this case, upon being served with the lawsuit and upon receiving the preservation letter, the defendant took no steps to timely collect evidence. It was not until nearly three months after Lilly was served with the complaint in this lawsuit, that someone searched Lilly’s servers for any electronic documents containing the word “Yale” in the file name. Lilly took no steps, of which the court is aware, to collect evidence from the key players or to search key players’ computers to see if ESI existed or had been deleted. It appears that Lilly left collection efforts to its employees to search their own computers with no supervision or oversight from management. Lilly did not follow up with its employees to determine what efforts were taken to preserve and collect relevant evidence, and Lilly failed to document any of its search and collection efforts. Indeed, it is not even clear who was in charge of the preservation, search, and collection efforts at Lilly. Although Lilly was probably not equipped to conduct computer searches itself, Lilly failed to retain a technical expert. In summary, after the duty to preserve was triggered, Lilly failed to timely issue an effective written litigation hold, to take appropriate steps to preserve any existing electronic records, to suspend or alter automatic delete features and routine overwriting features, and to timely and effectively collect ESI. Therefore, the court finds that Lilly breached its duty to preserve relevant evidence. See Naaco Materials v. Lilly Group, No.11-2415, 2011 WL 5986649 (W.D.Tenn. Nov. 16, 2011).