In Lake v. City of Phoenix, the Arizona Court of Appeals faced the question of whether metadata embedded within an electronic document is accessible under Arizona’s public-records statute. Lacking a statutory definition of “public record,” the court relied on Arizona common-law definitions from Mathews v. Pyle and Salt River Pima-Maricopa Indian Community v. Rogers. The majority viewed metadata as a mere “by-product” of the underlying public document, and held that it was not independently accessible under the statute. Judge Patricia K. Norris, in a dissenting opinion, argued that metadata was “integral to the original electronic documents,” and as such, should be accessible just like a paper copy. This Case Note addresses several post-Lake questions.