Hynix Semiconductor Inc. v. Rambus Inc.
In analysis of issue of spoliation of documents, standard for determining whether litigation was reasonably foreseeable at time documents were destroyed does not carry gloss requiring that litigation be “imminent, or probable without significant contingencies”; district court in present action applied improper standard in concluding that litigation was not reasonably foreseeable at time patentee shredded documents, and that patentee therefore did not engage in spoliation.