 Modern document review platforms accommodate the use of native files, and allow for them to be converted to TIFF and Bates-stamped for use in court.In 2006, the U.S. Supreme Court's amendments to the Federal Rules of Civil Procedure created a category for electronic records that, for the first time, explicitly named emails and instant message chats as likely records to be archived and produced when relevant.One type of preservation problem arose during the "Zubulake v. UBS Warburg" LLC lawsuit.