Although e-discovery has been part of complex commercial litigation for over a decade, there have been only a few federal appellate court rulings about e-discovery topics. On April 7, 2016, in In re Am. Nurses Ass’n, the Fourth Circuit became the latest appellate court to issue such a ruling. The Court upheld a district court’s ruling that shifted a third-party’s subpoena-related e-discovery costs to the subpoenaing party. The Court also upheld the lower court’s determination that attorney’s fees incurred by the third-party in responding to the subpoena should also be shifted to the subpoenaing party. The opinion is instructive to litigants and counsel on both sides of a subpoena.