The district court did not abuse its discretion in awarding terminating sanctions under FRCivP 37(e) against plaintiff for intentionally deleting (and getting her friends to delete) text messages about the case from their cellphones. There was substantial evidence that plaintiff acted intentionally to destroy the text messages and deprive defendant of their contents.  And lesser sanctions would not remedy that loss.  Evidence of prejudice to the opposing party does not need to be found since intentional destruction of evidence allows an inference of prejudice.