*4 The Court has the authority under Rule 37(b)(2) to impose discovery sanctions when a party “fails to obey an order to provide or permit discovery.” Fed.R.Civ.P. 37(b)(2). The court can issue an order: (1) establishing facts; (2) precluding claims or defenses or the introduction of designated matters into evidence; (3) striking pleadings, staying proceedings, or dismissing the action; or (4) finding contempt of court. See id.
In addition, the court may require the sanctioned party or attorney or both “to pay the reasonable expenses, including attorney's fees, caused by the failure” for which the sanctions were ordered. Id.
Violation of a court order regarding discovery is generally necessary to trigger the discovery sanctions of Rule 37(b). Unigard Sec. Ins. Co. v. Lakewood Eng'g & Mfg. Corp., 982 F.2d 363, 367–68 (9th Cir.1992); accord
Shepherd v. American Broad. Cos., Inc., 62 F.3d 1469, 1474 (D.C.Cir.1995). Here, Defendant violated at least three discovery orders of the Court
by failing to produce the person(s) most knowledgeable for deposition or to produce the current and prior versions of Defendant's web site, both of which were relevant to the discovery of Defendant's contacts with California for purposes of personal jurisdiction, and by tampering with the log files and deleting evidence in contravention of the August 24, 2001 order.