Since the 2007 amendments to the FRCP, commentators have been speculating that Rule 34 requires the production of electronically stored information in its "native" format.  Rule 34 states, in the absence of a specific request, electronic data can be produced as it is ordinarily maintained or in a reasonably usable form.  Recently, Judge Facciola underscored this point in D'Onofrio v. SFX Sports Group, Inc., 2008 U.S. Dist. LEXIS 4252 (D.D.C. Jan. 23, 2008), where he rejected a party's request for native files when the party failed to follow the procedures set forth in the FRCP.