Client issue: Our client, a global technology leader, was the defendant in a sprawling multi-district litigation, involving a complex array of plaintiffs, including State Attorneys General, numerous school districts, boards of education, and thousands of individuals. The size and sensitivity of the case required a trusted eDiscovery partner to manage an unprecedented volume of electronically stored information (ESI) from thousands of custodians across the US and European Union.
Key challenges included:
- Petabyte-Scale data across a global enterprise: Navigating a massive volume of ESI, originating from a diverse range of corporate data sources, including user workstations, laptops, mobile devices, emails, network shares, messaging platforms, audio/video, and user-generated content (UGC).
- Aggressive timelines and public scrutiny: Adhering to compressed deadlines for defensible collections, processing, review, and production, all while under intense media and regulatory scrutiny.
- Highly sensitive and regulated data: Securely handling highly sensitive internal communications reflecting internal knowledge and strategic discussions, complicated by cross-border data privacy regulations like General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), which dictated stringent protocols for data transfer and review.
- Controlling exploding costs: Implementing strategies to effectively manage and mitigate the immense, long-term costs associated with such protracted, large-scale litigation(s).
CRA approach: We partnered with the client to implement a robust, end-to-end eDiscovery solution:
- Scalable infrastructure and efficient ingestion: We rapidly established a centralized, highly scalable eDiscovery infrastructure, capable of ingesting, processing, and hosting hundreds of terabytes of diverse data with a maximum throughput of 30TB monthly.
- MDL-specific protocol development: We developed and implemented tailored ESI protocols and workflows, facilitating meticulous consistency across all pooled cases and strict compliance with the MDL court’s specific directives.
- Expert review management: We expertly managed a 200+ strong, multi-tier document review team, ensuring unparalleled accuracy, defensibility, and efficient privilege logging across the vast dataset.
- Advanced AI-driven analytics: Leveraging innovative technologies like Technology-Assisted Review (TAR), conceptual clustering, and communications analysis, we efficiently identified common issues, prioritized key documents, and streamlined data review by issue group or plaintiff cohort. This also included deploying Relativity AI Review (aIR) for expedited third-party production review.
- Specialized support for plaintiff data: We provided specialized support for managing plaintiff fact sheets and medical record review, including critical data abstrCRA Approach: and analysis to identify commonalities and differentiators among claimants.
- Strategic reporting and trial support: Our comprehensive reporting and metrics provided counsel with data-driven insights crucial for litigation strategy. We also delivered rapid-response data processing and production to support trial teams for bellwether selections, deposition preparation, and exhibit management.
Client impact: The MDL remains ongoing, and our client has successfully navigated the intricate complexities of the discovery phase, efficiently managed an unprecedented volume of data, and consistently met substantial completion deadlines.
By implementing our standardized, technology-driven approach, we not only facilitated the highest levels of defensibility and compliance but also achieved a projected 20%-30% reduction in overall discovery costs compared to traditional methods for this scale of litigation. This partnership empowered our client to focus on litigation strategy, confident in the integrity and efficiency of their eDiscovery operations.
