On January 13, 2011, the California Supreme Court decided Holmes v. Petrovich Development Co. In the case, plaintiff Gina Holmes sued her former employer for sexual harassment, retaliation, wrongful termination, violation of the right to privacy, and intentional infliction of emotional distress. However, before ever initiating suit, she used her company-provided computer to send emails to her attorney regarding possible legal action against that very same company employing her.