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We all use the cloud; it is also known as the Internet. However, many of us would rather avoid the preservation and discovery headaches caused by electronically stored information (ESI) in the cloud. E-discovery is hard enough on the ground. A recent opinion from a federal district court in Ohio, Brown, et al. v. Tellermate Holdings Ltd., et al, illustrates how these cloud-based e-discovery headaches can arise, and how they can be avoided.