We propose discussing the potential relevance of IoT data to different corporate or civil case scenarios, and the potential need for obtaining discovery from, for example, internet-connected cameras; home automation systems; smart speakers, TVs, and refrigerators, and wearables.

We would not discuss data generated by motor vehicles, i.e. black box, infotainment systems, and parking or other sensors as there is training and software available for that.

In the industrial realm we will discuss the challenge of IoT data generated in factories, warehouses, and pipelines, among other settings. We can also provide a summary of the limited case law related to IoT discovery issues.

• What is IoT?
• Consumer IoT
• Wearables
• Digital Assistants
• Smart Home devices (thermostats, light bulbs, doorbells, refrigerators, e.g.)
• Industrial IoT
• Safety and maintenance monitoring
• Supply Chain tracking and monitoring
• Productivity tracking and monitoring
• Unique IoT Challenges
• Use in Civil cases
• Preserving Data
• Helping clients understand what IoT data they have
• Who to send preservation request to?
• How to preserve?
• Collecting Data
• How to collect and from whom?
• Possession, Custody, and Control
• Consumer IoT
• Who owns the data?
• How and where is it stored?
• Industrial IoT
• Cloud-based monitoring systems or manufacturer IoT or LEASED IoT equipment
• Subpoenaing data from third parties
• Different formats and potential need to convert the data for review.

Assessing Accessibility, Relevance of IoT Data

• Often less accessible, but also more ephemeral, more danger of spoliation
• Is same data available from other, more easily accessible sources?
• Is all IoT data relevant?
• Can it be “untwined” if it’s massive?