The formalized changes to the Federal Rules of Civil Procedure in December 2006 and in 2007 effectively forced civil litigants into a compliance mode with respect to their proper retention and management of electronically stored information (ESI). Improper management of ESI can result in a finding of spoliation of evidence and the imposition of one or more sanctions including an adverse inference jury instructions, summary judgment, monetary fines, and other sanctions. In some cases, such as "Qualcomm v. Broadcom", attorneys can be brought before the bar.