The recent release of the Federal Rules of Civil Procedure (FRCP) has brought electronic discovery into the mainstream of litigation. With highly publicized bad experiences including large sanctions, cost-sharing orders and a largely untested judiciary, fear of uncontrollable costs has become commonplace. The recent update of the FRCP is now driving electronic discovery requirements down to the mid-size and even small law firms. As a result, electronic discovery will eventually become standardized by the industry but it is far from being a commodity today.