In Susquehanna International Group Ltd v Needham [2017] IEHC 706, the Irish High Court considered the novel question of whether a court could order a person to make a data access request in aid of making discovery of documents. Ultimately, the High Court held that it could compel a party making discovery to make a data access request in order to obtain documents which were within its power, where that request was not oppressive or disproportionate.