Law360, New York (July 10, 2015, 10:41 AM EDT) -- The Ninth Circuit Court of Appeals, following several of its sister courts, has recently held that machine "statements" are not hearsay and are, therefore, admissible evidence. United States v. Lizarraga-Tirado, No. 13-10530, (9th Cir. June 18, 2015). Lizarraga-Tirado implicitly affirms a Ninth Circuit district court decision that also held that metadata, the information that computers generate automatically and store in files and databases, is not hearsay. 1st Fin. SD, LLC v. Lewis, No. 2:11-CV-00481, (D. Nev. Oct. 5, 2012). This result is important for trade secret litigators who increasingly rely on the metadata of pilfered electronic documents that are produced in discovery to prove or disprove their case....