Unlike with a 5.1 or 7.1 surround - which offer five or seven surround speaker points with a single bass point - Atmos has
potentially unlimited range, to a maximum of 64 speaker fields (at present).
There was Hearsay, Notices to Produce and Admit, the Old Rule of Discovery and especially the glorious Peruvian Guano test (from Compagnie Financière du Pacifique v Peruvian Guano Co (1882) 11 QBD 55) permitting a virtually
unlimited range of
potentially relevant and therefore discoverable documents.