The Texas Twelfth District Court of Appeals upheld the verdict and the spoliation inference instruction. The preservation of metadata from electronic documents creates special challenges to prevent spoliation. The Department of State also settled smaller spoliation claims with Denmark, Portugal, and Spain. Consolidated Interrogations Reports (CIRs), and a "Red Flag list" of people involved in Nazi spoliation. The spoliation cases last over a century, from the 1790s until 1915. Campbell served as a member of the French Spoliation Claims Commission in 1831. He also managed a dispute with France, over what were known as the "Spoliation Claims". The cases, termed "French Spoliation Claims", continued in the court until 1915. Spoliation is the destruction or alteration of evidence through intention or ignorance. This was compared to a spoliation of the company's assets.