The ruling explicitly overrules Shih, thus making exactly that argument:

> Shih, of course, is not binding on this Court, and this Court respectfully disagrees with its holding. As relevant here, the court in Shih principally concluded that the work product doctrine is not limited to materials prepared by or at the direction of an attorney. Id. But that conclusion undermines the policy animating the work product doctrine, which, as one of the cases cited in Shih explains, is "to preserve a zone of privacy in which a lawyer can prepare and develop legal theories and strategy 'with an eye toward litigation.'"

Does that imply that materials produced by the client in conversation with the attorney (e.g. attorney says to client "Ok write here in your own words what happened so I can understand your perspective") are not privileged?

Or would those presumably exist under the umbrella of privacy because they're relevant to the lawyer preparing and developing their legal strategy?