The Southern District Court ruled in Nichols et al. v. Noom, Inc., no. 20-cv-3677 (Mar. 11, 2021) that, given lack of an exportable target, a hyperlink fails to become an attachment, and thus a producing party does not have to deliver anything more.
While the Court appreciates that hyperlinked internal documents could be akin to attachments, this is not necessarily so. When a person creates a document or email with attachments, the person is providing the attachment as a necessary part of the communication. When a person creates a document or email with a hyperlink, the hyperlinked document/information may or may not be necessary to the communication.