Slack And Collaborative Work Tools: The Proper Scope Of Discovery Of Slack Channels

Slack, the collaborative workspace designed to streamline real-time communications between business teams, poses some challenges in the eDiscovery context (see our prior blog post). This blog post discusses a recent decision that explores the proper scope of discovery regarding Slack messages – specifically, whether each individual Slack message should be treated as a discrete document under Rule 34, or whether a court should view an entire Slack channel as a single, continuous document.

Background

In Lubrizol Corp. v. IBM Corp., plaintiff alleged defendant breached a contract between the parties and committed fraud and various torts in connection with a project to implement new enterprise resource planning software known as S/4HANA. (ECF Doc. No. 60). Before the Magistrate was plaintiff (Lubrizol)'s motion to compel defendant International Business Machines Corporation (IBM) to produce Slack messages. (ECF No. 77).