IV. Conclusion-The Future?

It is only a matter of time before voicemail messages and instant messaging (IM) logs become part of the eDiscovery mix as well.254 Unified messaging-whereby each voicemail ends up as an attachment to an e-mail message received in one's e-mail Inbox-will likely be one catalyst. Individual, as opposed to entity, plaintiffs will probably be another. At some point, such individual plaintiffs, undaunted by mutually-assured-destruction reciprocal requests from entity defendants, will push the envelope.

Beware these next waves.