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The courts must face up to the problems of electronic mail and find a way to authenticate it under than the Rule 901 standards still used in the mid-1990s. The Federal Rules of Evidence do not directly deal with the reliability of computer evidence and only have had to address its admissibility with the business records exception of the hearsay rule. Due to the exponential growth of the Internet, courts will be sure to have to deal with the admissibility of e-mail which is not a business record and with authentication rules for such evidence under the Federal Rules of Evidence.
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