Skip to content

Federal court approves a TAR protocol agreed by Rio Tinto and Vale

In March 2015 a US magistrate judge approved the predictive coding protocol that Rio Tinto and Vale had agreed. He wrote that TAR must face no higher standard than keywords or manual review.

  • Not rated an organization

    The review had not run when the court approved the protocol, so the opinion reports no saving or accuracy for either company.

Depth runs from 1, a convenience or time saved, to 5, a life or a livelihood preserved.

Status
Intended benefit.
Evidence

found, the grade of this recordstudiedreportedclaimed

An independent court document supports the benefit.

Compared with

Keyword searches or manual review. Assumed without a measurement.

The system’s part
Not isolated. The court approved a protocol that the parties had agreed and tested neither tool. The opinion reports no result from the review. The parties' letter describes models built from the coding of a review team, one of them on the LibLinear classification library.
Not yet checked
LimitsCosts and harmsLearns from dataLater outcome
Benefit type
Reduced Task Cost
System
Relativity Assisted Review (Rio Tinto) and Deloitte's Dynamic Review (Vale), under a stipulated predictive coding protocol
Made by
Relativity (Relativity Assisted Review) and Deloitte (Dynamic Review), as the parties' letter attached to the opinion names the tools
Used by
Rio Tinto plc (plaintiff), with its vendor Precision Discovery, and Vale S.A. (defendant)
Where
New York, United States
Stage
Proposed
Date
, when the source was published
Kind
Benefit created
Broad benefit
Processing Information, Getting Information
Collections
Scrutiny and findings
Last revised
1 November 2026

Sources

  1. Court document, by authors with no tie to the system.

    United States District Court for the Southern District of New York (Magistrate Judge Andrew J. Peck). Rio Tinto PLC v. Vale S.A., 306 F.R.D. 125 (S.D.N.Y. 2015), Opinion and Order of 2 March 2015, with the parties' letter and stipulated protocol attached as an appendix. Caselaw Access Project copy of the Federal Rules Decisions report.

    The Court is approving the parties' TAR protocol, but notes that it was the result of the parties' agreement, not Court order.

Details

AI system

Workflow

Rio Tinto and Vale agreed on a predictive coding protocol and asked the court to approve it. Each responding party reviews a random control set, trains the software on seed and training sets and discloses estimated recall and precision. Before production, each party reviews a sample of the documents that the software marks likely non-responsive and discloses the implied recall.

Follow-up

Conditions for replication

The parties disclose to each other the non-privileged documents in their control, seed and training sets. Samples are large enough for a margin of error of plus or minus 2% at the 95% confidence level. The court holds TAR to no higher standard than keywords or manual review.

Entry details

Sector

Legal services / e-discovery.

Purpose

Relativity built Relativity Assisted Review and Deloitte built Dynamic Review to sort documents as likely responsive or not, learning from the coding that lawyers give to samples.

31 more questions not yet checked

model, release, provider, role, configuration, inputs and outputs, autonomy, human oversight, AI contribution, beneficiaries, reach, distribution and access, duration, every measurement question, every money question, ownership and control, dependencies, cross-border connections, geopolitical implications, replication attempts, availability, institutional decision, grounds, action and result, success criterion, every evidence question, observed or intended, alternative assessments, related entries, other identifiers, category mappings.

Cite this record

Peter H. Vartanian. (2026). Federal court approves a TAR protocol agreed by Rio Tinto and Vale (AIBD-0981). Artificial Intelligence Benefits Database, edition of 1 November 2026. https://petervartanian.xyz/aibd/records/AIBD-0981.html (archived at https://doi.org/10.7910/DVN/AADSII, version 7.0)

BibTeX Data Field definitions