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Many companies are tempted to seek cost savings relating to electronic discovery by conducting some or all aspects of the process in-house. It is undeniably true that these efforts could save significant money in your e-discovery budget. But, as the recent decision in National Day Laborer Organizing Network et al. v. U.S. Immigration and Customs Enforcement Agency, et al. (NDLON) suggests, these efforts are also likely to meet skepticism, or even disfavor, and may result in sanctions, court orders that require duplication of effort or other unexpected costs.