They reason that, because Citric Acid cited decisions from other circuits that "adopted a more expansive definition of 'legal control,'" the Ninth Circuit would approve looking at other factors that suggest control might exist even in the absence of a "legal right to obtain documents on demand." See Doc. No. 247 at 12-14 & n.7. For example, Plaintiffs urge the court to follow the reasoning of AFL Telecommunications LLC v. SurplusEQ.com, Inc., 2012 U.S. Dist. LEXIS 92892 (D. Az. July 5, 2012) and the cases on which it relies. See Doc. No. 247 at 16; Doc No. 251 at 2-5.