Our Client, the defendant in a putative class action litigation, asked for our help to deal with a burdensome Request for Production. We were presented with roughly 500 gigabytes of data, or almost a million documents to review. We were able to reduce the review set size to less than 80,000 using traditional search term methodology in conjunction with Relativity Analytics, a 90% reduction. This is a respectable data reduction, but we didn’t stop there.
A Holistic Approach
Trustpoint approaches early case assessment with a mindset of achieving defensible data reduction. We do not set our sights on any preconceived number of documents or an arbitrary finish line. Instead, we operate with the mindset that we should reduce the attorney review set as much as is safely defensible. Working from that basic principle, we continued to analyze the 80,000 document attorney review set for further reduction opportunities. What we noticed was the review set was inordinately rich in spreadsheets. Deeper analysis of these documents’ family structure and the nature by which traditional search terms captured them showed that they may be redundant to in-house counsel’s separate production efforts. After approaching the Client with our observation and confirming that they had already produced such information, we realized that these documents could be defensibly eliminated as duplicative. After the Client confirmed as much through null set validation, the review set was effectively reduced from about 80,000 documents to about 12,000 documents. This was an additional 85% reduction for a final cull rate of 99%.
This solution was made possible by our holistic approach to data analysis, and would not have been solved by relying on traditional search term methodology, predictive coding/machine learning, or Relativity Analytics alone. Our initial data reduction efforts using traditional methodology took this review from a $1M+ budget to somewhere between $100K and $200K. This represented a significant cost-savings that many clients would have been pleased with and “green lighted”. However, we consider data reduction to be an on-going process, and so we identify and present all of our Client’s available options. By continuing to press for data reduction options, we ultimately billed our Client less than $40,000 (and that included a complete privilege log, extensive custom redactions, and all early case assessment consulting costs). While we cannot guarantee similar results for all matters and data sets, we can provide our clients ease of mind knowing that if there is an available solution to avoid unnecessary review costs, we will find and present it.