{"id":"AIBD-0983","title":"A Tennessee federal court let Bridgestone review over two million documents with predictive coding over IBM's objection, citing efficient discovery","summary":"In July 2014 a US magistrate judge let Bridgestone review over two million documents with predictive coding, over IBM's objection. He cited Rule 26's call for efficient, cost-effective discovery.","date_observed":"2014-07-22","date_basis":"source publication","date_precision":"day","benefit_status":"intended","source_collection":null,"source_entry":null,"account":"Bridgestone Americas sued IBM in the federal court in Nashville. After screening its documents with search terms that IBM had provided, Bridgestone asked to review something over two million of them with predictive coding. IBM objected that this changed the case management order and that predictive coding after a search term screen was unfair. On 22 July 2014 Magistrate Judge Joe B. Brown allowed it. He wrote that using predictive coding is a judgment call under Rule 26, which asks that discovery be as efficient and cost-effective as possible. He noted that millions of documents were at stake, with costs likewise in the millions. Because Bridgestone was switching methods midstream, he expected full openness. Bridgestone offered to share its seed documents. IBM, a third to half done with its manual review, stayed free to switch too. The order compares no costs and reports no result, and the review had not run. In January 2015 the parties told the court that some seed documents listed as nonresponsive were in fact responsive.","category":"benefit created","unexpected":false,"purpose":"A vendor that the order does not name built the predictive coding software to rank documents for responsiveness, starting from seed documents that reviewers code.","system":"Predictive coding","model_version":null,"developer":"Not named in the order","deployer":"Bridgestone Americas, Inc. 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He cited Rule 26's call for efficient, cost-effective discovery.","account":"Bridgestone Americas sued IBM in the federal court in Nashville. After screening its documents with search terms that IBM had provided, Bridgestone asked to review something over two million of them with predictive coding. IBM objected that this changed the case management order and that predictive coding after a search term screen was unfair. On 22 July 2014 Magistrate Judge Joe B. Brown allowed it. He wrote that using predictive coding is a judgment call under Rule 26, which asks that discovery be as efficient and cost-effective as possible. He noted that millions of documents were at stake, with costs likewise in the millions. Because Bridgestone was switching methods midstream, he expected full openness. Bridgestone offered to share its seed documents. IBM, a third to half done with its manual review, stayed free to switch too. The order compares no costs and reports no result, and the review had not run. In January 2015 the parties told the court that some seed documents listed as nonresponsive were in fact responsive."}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["summary","account"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"systems[].autonomy_permissions":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].component_role":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].deployment_configuration":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].inputs_outputs":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].model_name":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].model_version":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].product_name":{"state":"value_present","value":{"kind":"record_fields","fields":{"system":"Predictive coding"}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["system"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"systems[].provider":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"taxonomy_crosswalks[]":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"title":{"state":"value_present","value":{"kind":"record_fields","fields":{"title":"A Tennessee federal court let Bridgestone review over two million documents with predictive coding over IBM's objection, citing efficient discovery","headline":"Court lets Bridgestone use *predictive coding* over IBM's objection"}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["title","headline"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"version":{"state":"value_present","value":{"kind":"identifiers","identifiers":["45e6ea40787f762d3bca0c8d35c645f6400e02713b33de37ae33c09884d6ff17"],"role":"SHA-256 of the complete public record and its assessments"},"provenance":{"kind":"curatorial","basis":"SHA-256 of the public record, its assessments, and its displayed answers and notes, excluding its own identifier and the derived coverage summary.","record_fields":[],"source_refs":[]},"review_state":"record_mapped","coverage":"complete"},"workflow":{"state":"value_present","value":{"kind":"record_fields","fields":{"account":"Bridgestone Americas sued IBM in the federal court in Nashville. After screening its documents with search terms that IBM had provided, Bridgestone asked to review something over two million of them with predictive coding. IBM objected that this changed the case management order and that predictive coding after a search term screen was unfair. On 22 July 2014 Magistrate Judge Joe B. Brown allowed it. He wrote that using predictive coding is a judgment call under Rule 26, which asks that discovery be as efficient and cost-effective as possible. He noted that millions of documents were at stake, with costs likewise in the millions. Because Bridgestone was switching methods midstream, he expected full openness. Bridgestone offered to share its seed documents. IBM, a third to half done with its manual review, stayed free to switch too. The order compares no costs and reports no result, and the review had not run. In January 2015 the parties told the court that some seed documents listed as nonresponsive were in fact responsive.","replication":{"produced_by":["Bridgestone first screened its documents with search terms that IBM had provided.","Bridgestone offered to share the seed documents that it used to set up predictive coding."],"must_hold":["Bridgestone stays open and transparent about how it uses predictive coding.","The parties confer often through their attorneys, experts and the companies doing the work.","The case schedule can absorb a later date for the first production."],"echoes":[]}}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["account","replication"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"}},"summary":{"total":91,"addressed":91,"known":28,"reviewed":2,"reviewed_complete":2,"reviewed_partial":0,"record_mapped":26,"review_not_assessed":63,"not_assessed":0,"complete":false,"by_state":{"value_present":28,"not_reported":0,"unresolved":63,"not_assessed":0,"not_applicable":0,"withheld":0,"source_unavailable":0}}},"presentation_version":"62b24bc0013b20e986979b716185ff5015994ba81ee1ec2eebc8f913638b53f8"}