Discovery of Microsoft Teams messages: Takeaways from Valcrum, LLC v. Dexter Axle Co.

With the use of chat-based communications in the workplace, such as Microsoft Teams (Teams), courts are confronting how these communications should be collected, searched, and produced in litigation. In Valcrum, LLC v. Dexter Axle Co., No. 3:24-cv-190 (N.D. Ind. July 15, 2026), the court addressed these issues directly, offering practical guidance on production format, contextual review, supplementation obligations, and the limits of keyword-based searches for Teams data.

Below, we discuss the background of the case, summarize the court’s reasoning, and offer practical implications for parties involved in litigation.

Background

In Valcrum, the court addressed a discovery dispute over Teams messages exchanged among Dexter employees in a trademark and trade-dress action concerning competing hubcap designs. Dexter initially produced individual Teams messages on a rolling basis across ten production volumes.

In a final production volume, Dexter produced additional messages as chronologically organized conversational threads, which Valcrum contended combined new and previously produced material and included redactions for non-relevant content. Valcrum moved to compel production of full conversations and unredacted thread productions, arguing that the changing formats and lack of context impaired its use of the messages in witness depositions.

The court’s reasoning

The court’s findings included the following considerations:

• Production format and storage architecture. Rule 34(b)(2)(E) governs production of electronically stored information (ESI), including Teams messages. The court noted a split of authority regarding whether subsection (ii) alone governs ESI productions or whether subsection (i) also requires parties to produce ESI as kept in the usual course of business or to organize and label it to correspond with discovery requests. Under either approach, a party claiming to have produced ESI in the ordinary course of business must demonstrate that the production did not alter the manner in which the data is ordinarily maintained. Where no form is specified, Rule 34 permits production in the form in which the ESI is ordinarily maintained or in another reasonably usable form (emphasis added), and a party need not produce the same ESI in more than one form.
  
  Dexter explained that the Teams messages were stored in the inbox of each custodian participating in a conversation, rather than as preassembled conversation threads. Because Dexter demonstrated that its production reflected the platform’s native storage architecture, the court declined to require it to reconstruct and produce complete Teams conversations. This decision highlights the importance of understanding both a platform's underlying data architecture and the available eDiscovery tools when litigating production-format disputes. While Teams messages may be stored as individual messages rather than as assembled conversations, parties seeking or opposing threaded productions are encouraged to address not only how the data is maintained in the ordinary course, but also whether conversation-threading technology can reconstruct the data in a reasonably usable form and any associated burdens.


• Keyword searches are insufficient. The court rejected a rigid search-term-only approach, reasoning that because Teams conversations are shorter, more informal, and less likely than email to contain full names, keyword hits may miss responsive messages and surrounding context. As a result, parties are encouraged to consider collecting and reviewing messages based on participants, communication strings, dates, and surrounding communications rather than relying exclusively on search terms.


• A targeted contextual remedy. Valcrum sought full Teams correspondence, but the court rejected that remedy as overly broad. Instead, it ordered production of Teams messages on the same communication string sent during the three days before and after each already-produced message, including messages from or directed to each relevant custodian. This approach balanced the need for conversational context against the burden of reconstructing complete threads and kept discovery within relevant bounds. The court also required unredacted copies of threaded Teams conversations that had already been produced.


• Specific objections and potential for waiver. The court ordered unredacted versions of the threaded Teams conversations after Dexter did not explain why they should remain redacted. Objections that a request was overly broad, unduly burdensome, vague, ambiguous, or disproportionate were considered insufficient without supporting detail. The court held that any reflexive, nonspecific objections are waived. The threaded Teams conversations therefore had to be produced in their entirety.


• Duty to supplement. Under Rule 26(e), Dexter’s duty to supplement its discovery responses was automatic and did not require Valcrum to issue supplemental discovery requests. The court rejected Dexter’s argument that Valcrum’s delay in issuing its Third Requests for Production justified denial of the motion to compel.

Practical implications

For litigators and organizations handling discovery involving Teams communications, Valcrum offers a set of practical guidelines on how chat data can be preserved, searched, produced, supplemented, and challenged:

1. Specified contextual windows. Where contextual production is appropriate, parties are encouraged to consider negotiating a methodology that balances the need for context against the burden of production. In Valcrum, the court ordered production of messages on the same communication string sent during the three days before and after each responsive message. Other courts have approved narrower contextual windows by party agreement, including 24-hour windows surrounding responsive chat messages. The practical lesson is that parties can develop and negotiate a context-production methodology tailored to the platform, issues, and burden considerations in the case, rather than risk having the court impose one of its own.


2. Overreliance on keyword searches for Teams. Because Teams chats are short, informal, and often omit full names, a search built around email-style keywords may miss relevant messages and surrounding context. Parties are encouraged to ensure that collection and review account for custodians, participants, communication strings, channels, date ranges, and surrounding messages, using more advanced and thoughtful techniques where necessary.


3. Understanding how Teams stores data before collecting and producing it. Rule 34(b)(2)(E) permits production of ESI as it is ordinarily maintained or in a reasonably usable form and does not require duplicate production in more than one form. Because Microsoft stores individual Teams messages in each participating custodian’s inbox rather than as separate threads, a responding party may not be required to build complete threads – but it should be able to explain the platform’s storage architecture and preserve usable context. Parties are encouraged to consult information technology (IT), a vendor, or similar professional that understands the environment where the Teams data is stored and the most efficient and defensible ways to collect it.


4. Coming to agreement on the Teams production format early. Parties are encouraged to negotiate the production format for Teams messages in their ESI protocol or otherwise reach agreement before production begins, including how messages will be organized and what metadata and contextual information will accompany them. Advance agreement may help avoid disputes over the format and scope of production and reduce the risk that the court will have to decide those issues after production has begun. Consulting IT, a vendor, or similar professional may be beneficial, as parties are encouraged not to agree to a production format with which they cannot comply.


5. Specifying objections to Teams requests. Objections that merely recite that a request is overly broad, unduly burdensome, vague, ambiguous, or disproportionate are vulnerable to waiver. Valcrum required unredacted threaded conversations because the objections lacked supporting detail.


6. Addressing relevancy-based redactions through a meet and confer. Parties are encouraged to discuss whether potentially non-relevant or highly sensitive business information may be redacted from otherwise responsive Teams conversations. Where concerns cannot be resolved, an Attorney’s Eyes Only (AEO) designation or other protective-order mechanism may provide a more defensible alternative than broad relevancy redactions.


7. Addressing preservation at the outset. Litigation holds should expressly identify Teams direct messages, channels, and other chat-based platforms used by relevant custodians. Automated deletion policies should be identified and suspended where necessary, and retention and archiving settings should be documented. In addition, counsel is encouraged to coordinate with IT personnel and relevant custodians to understand platform-specific retention and deletion behavior, including where messages and related data are stored, so that the hold preserves both the communications and the context needed to collect and produce them.

Conclusion

Valcrum demonstrates that when parties fail to agree upfront on the format and scope of Teams production, courts may impose a contextual remedy of their own – such as a three-day production window around each already-produced message – to supply useful context without requiring reconstruction of complete threads. The decision also underscores that a producing party is responsible for understanding how the platform stores data, and may not alter the production format in a way that obscures how the data is ordinarily maintained. Boilerplate objections unsupported by specific details are subject to waiver, and parties are encouraged not to assume that a request for supplemental production is a prerequisite to the responding party’s obligation: Under Rule 26(e), the duty to supplement is automatic and ongoing.

The case also highlights that Teams discovery requires more than email-style keyword searches, but does not require a producing party to reconstruct every conversation. Organizations are encouraged to address Teams storage, preservation, production format, and contextual search strategies early and state objections with supporting detail to reduce the risk of piecemeal productions and court-ordered supplementation or unredacted production.

For more information about how this decision may affect your organization’s eDiscovery practices, please contact DLA Piper’s eDiscovery and Information Management practice group.