Native production
Native production in eDiscovery is the production of documents in the file format in which they were created (a spreadsheet as .xlsx, a presentation as .pptx, an email as .msg) rather than as static images. It preserves what imaging discards: formulas, hidden rows and sheets, speaker notes, comments, tracked changes and embedded objects. A Bates-numbered placeholder accompanies each file.
Also called: native file · native format · native format production · native with placeholder · near-native
Updated September 6, 2026
How does native production work?
Under Rule 34(b)(2)(E)(ii), absent agreement or request, ESI must be produced in the form in which it is ordinarily maintained or in a reasonably usable form. Native is the form in which it is ordinarily maintained. Most ESI protocols adopt a hybrid: image most document types, produce spreadsheets, presentations, audio, video and databases natively.
Each native file is assigned a single Bates number, applied to its file name and to a one-page slip sheet that stands in for it in the image set. The load file references the native through a NATIVELINK field. Native files are hashed so their integrity can be verified after delivery.
What does native production look like in practice?
The format risk planner rates each file type. The ones that lose content on imaging and should be produced native:
| File type | What imaging loses |
|---|---|
| Spreadsheets | Formulas, hidden rows/columns/sheets, comments, cell formatting |
| Presentations | Speaker notes, hidden slides, animations, embedded media |
| Files with macros or embedded objects | The macros and objects |
| Audio and video | Everything: there is no page to image |
| Databases | Everything: produced by agreed report instead |
How does native production show up on an eDiscovery invoice?
Native production is usually cheaper than imaging. Format conversion or TIFFing fees are charged per page or per gigabyte, and a single large spreadsheet can image to thousands of pages. A protocol that keeps spreadsheets and presentations native removes most of that line. The cost that remains is the production export fee itself, which is typically per gigabyte regardless of form. Ask whether native production is supported without a surcharge and whether slip sheets are generated automatically.
Sources
- Fed. R. Civ. P. 34(b)(2)(E)(ii).
- Model ESI orders requiring native production of spreadsheets and presentations (e.g., N.D. Cal. Model Stipulated Order Re: Discovery of ESI).
- The Sedona Conference Glossary, “native format.”
Related terms
TIFF production · Slip sheet · Bates numbering · Redaction · ESI protocol · Metadata
eDiscovery at one flat monthly rate
$3,250 a month on a 12-month agreement. No per-user fees and no per-GB hosting charges.
Common questions
What is the difference between native and TIFF production?
TIFF production converts every page to a static image, stamps it, and delivers extracted text alongside. Native production delivers the original file. Images are easy to number and redact but lose any content that does not print; natives preserve everything but are harder to stamp and cannot be redacted without altering the file.
Should spreadsheets be produced native?
Almost always. A spreadsheet imaged to TIFF loses formulas, hidden rows and columns, hidden worksheets and cell comments, and a large sheet can run to thousands of pages. Most model ESI orders require native production of spreadsheets and presentations for this reason.
How is a native file redacted?
Usually it is not. The standard approach is to image the specific document, redact the image, and produce it as TIFF notwithstanding the native requirement. The ESI protocol should say so. Native redaction tools exist for some formats but alter the file and its metadata, which must be disclosed.