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The growing deployment of lithium-ion (Li-ion) batteries in data centers is prompting discussion on the potential use of those batteries to provide some level of grid services, such as regulation or primary frequency response. Indeed, in the energy storage world it has long been the aim to address multiple applications to create stacked financial benefits, so it seems logical to consider using these batteries for grid services while maintaining an energy reserve for standby operation. The cycling capability of most Li-ion batteries certainly can support this type of use, but is it a good idea? This paper provides information on the operation of Li-ion energy storage systems in regulation and frequency-response applications, and how these services can be adapted for data-center batteries. The dynamics of markets for these services are also discussed. It will be seen that this combination of applications, while technically feasible, is not without complications.