{"id":"AIBD-0988","title":"The Circuit Court for Loudoun County, Virginia, let the Landow defendants use predictive coding in the Dulles Jet Center cases over objections","summary":"In April 2012 a Virginia state court let the defendants in the Dulles Jet Center hangar-collapse cases use predictive coding over objections. The order gives no reasons.","date_observed":"2012-04-23","date_basis":"source publication","date_precision":"day","benefit_status":"intended","source_collection":null,"source_entry":null,"account":"Three hangars at the Dulles Jet Center in Loudoun County, Virginia, collapsed in a snowstorm in February 2010, and the lawsuits were consolidated in the county's circuit court. Other parties objected when the Landow defendants proposed predictive coding for their electronic files. In their memorandum, the defendants estimated that linear review of more than two million documents would take 20,000 hours and cost two million dollars. They claimed that predictive coding could find upwards of seventy-five percent of the potentially relevant documents at a fraction of the cost. On 23 April 2012 Judge James H. Chamblin ordered that the defendants be allowed to proceed with predictive coding. Handwritten terms in the order allowed 60 days for processing and up to 60 more for production. A receiving party could still raise the completeness of the production or the ongoing use of predictive coding with the court. Counsel for one plaintiff signed the order as seen and objected to. The order gives no reasons and no finding on cost or accuracy, and the review had not run.","category":"benefit created","unexpected":false,"purpose":"A vendor that the order does not name built the predictive coding tool to separate relevant from irrelevant documents, with a model trained on an attorney's coding.","system":"Predictive coding","model_version":null,"developer":"Not named in the order or in the defendants' memorandum","deployer":"Landow Aviation Limited Partnership, Landow Aviation I, Inc. and Landow & Company Builders, Inc. 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Landow Aviation, L.P. d/b/a Dulles Jet Center, et al., Consolidated Case No. CL 61040, Order Approving the Use of Predictive Coding for Discovery, entered 23 April 2012. Copy of the signed order on the eDiscovery Law blog of K&L Gates.","title":"Order Approving the Use of Predictive Coding for Discovery","url":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/Order-Approving-Predictive-Coding-.pdf","date":"2012-04-23","written_by":"independent","quote":"Having heard argument with regard to the Motion of Landow Aviation Limited Partnership, Landow Aviation I, Inc., and Landow & Company Builders, Inc., pursuant to Virginia Rules of Supreme Court 4:1(b) and (c) and 4:15, it is hereby ordered Defendants shall be allowed to proceed with the use of predictive coding for purposes of the processing and production of electronically"},{"kind":"other","citation":"Landow Aviation Limited Partnership, Landow Aviation I, Inc. and Landow & Company Builders, Inc. Memorandum in Support of Motion for Protective Order Approving the Use of Predictive Coding, Circuit Court for Loudoun County, Consolidated Case No. CL 61040, served 9 April 2012. Copy on the eDiscovery Law blog of K&L Gates.","title":"Memorandum in Support of Motion for Protective Order Approving the Use of Predictive Coding","url":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/MemoSupportPredictiveCoding.pdf","date":"2012-04-09","written_by":"deployer","quote":"Predictive coding, on the other hand, is capable of locating upwards of seventy-five percent of the potentially relevant documents and can be effectively implemented at a fraction of the cost and in a fraction of the time of linear review and keyword searching."}],"replication":{"produced_by":["The defendants held an estimated 250 gigabytes of reviewable electronic files.","An attorney codes training documents until the tool stabilizes, and the tool then applies its model to the collection.","The defendants offered to give opposing counsel the training documents, apart from privileged documents and sensitive irrelevant ones."],"must_hold":["Processing finishes within 60 days, and production follows within a further 60 days.","A receiving party can still raise the completeness of the production with the court.","The coding goes on until the recall measured on samples reaches at least 75%."],"echoes":[]},"paired_incident":null,"headline":"Virginia court lets defendants use *predictive coding* over objections","metric":null,"comparator":null,"later":null,"value":null,"developer_country":null,"deployer_country":"United States","unrated_because":"The court allowed predictive coding before the review ran, and the order reports no result.","brief_notes":null,"brief":null,"revisions":[{"date":"2026-11-01","change":"Added the record from the finding of the Circuit Court for Loudoun County, Virginia.","source":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/Order-Approving-Predictive-Coding-.pdf","editor":"AIBD"}],"confidence":"found","shade":"high","claim_status":"Found by a court","claim_basis":"Sources: one independent court document and the deployer's other source. 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Copy on the eDiscovery Law blog of K&L Gates.","title":"Memorandum in Support of Motion for Protective Order Approving the Use of Predictive Coding","url":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/MemoSupportPredictiveCoding.pdf","date":"2012-04-09","written_by":"deployer","quote":"Predictive coding, on the other hand, is capable of locating upwards of seventy-five percent of the potentially relevant documents and can be effectively implemented at a fraction of the cost and in a fraction of the time of linear review and keyword searching."}]}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["evidence"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"sources[].id":{"state":"value_present","value":{"kind":"identifiers","identifiers":["AIBD-0988-source-0001","AIBD-0988-source-0002"],"role":"Existing evidence items, in their original order"},"provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"review_state":"record_mapped","coverage":"complete"},"sources[].language":{"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"},"sources[].relationship":{"state":"value_present","value":{"kind":"record_fields","fields":{"evidence":[{"kind":"court document","citation":"Circuit Court for Loudoun County, Virginia (Judge James H. Chamblin). Global Aerospace Inc., et al. v. Landow Aviation, L.P. d/b/a Dulles Jet Center, et al., Consolidated Case No. CL 61040, Order Approving the Use of Predictive Coding for Discovery, entered 23 April 2012. Copy of the signed order on the eDiscovery Law blog of K&L Gates.","title":"Order Approving the Use of Predictive Coding for Discovery","url":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/Order-Approving-Predictive-Coding-.pdf","date":"2012-04-23","written_by":"independent","quote":"Having heard argument with regard to the Motion of Landow Aviation Limited Partnership, Landow Aviation I, Inc., and Landow & Company Builders, Inc., pursuant to Virginia Rules of Supreme Court 4:1(b) and (c) and 4:15, it is hereby ordered Defendants shall be allowed to proceed with the use of predictive coding for purposes of the processing and production of electronically"},{"kind":"other","citation":"Landow Aviation Limited Partnership, Landow Aviation I, Inc. and Landow & Company Builders, Inc. Memorandum in Support of Motion for Protective Order Approving the Use of Predictive Coding, Circuit Court for Loudoun County, Consolidated Case No. CL 61040, served 9 April 2012. Copy on the eDiscovery Law blog of K&L Gates.","title":"Memorandum in Support of Motion for Protective Order Approving the Use of Predictive Coding","url":"https://www.ediscoverylaw.com/wp-content/uploads/2013/11/MemoSupportPredictiveCoding.pdf","date":"2012-04-09","written_by":"deployer","quote":"Predictive coding, on the other hand, is capable of locating upwards of seventy-five percent of the potentially relevant documents and can be effectively implemented at a fraction of the cost and in a fraction of the time of linear review and keyword searching."}]}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["evidence"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"sources[].upstream_sources":{"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"},"strategic_assessments[]":{"state":"unresolved","review_state":"not_assessed","coverage":"partial","family":"strategic assessments"},"summary":{"state":"value_present","value":{"kind":"record_fields","fields":{"summary":"In April 2012 a Virginia state court let the defendants in the Dulles Jet Center hangar-collapse cases use predictive coding over objections. The order gives no reasons.","account":"Three hangars at the Dulles Jet Center in Loudoun County, Virginia, collapsed in a snowstorm in February 2010, and the lawsuits were consolidated in the county's circuit court. Other parties objected when the Landow defendants proposed predictive coding for their electronic files. In their memorandum, the defendants estimated that linear review of more than two million documents would take 20,000 hours and cost two million dollars. They claimed that predictive coding could find upwards of seventy-five percent of the potentially relevant documents at a fraction of the cost. On 23 April 2012 Judge James H. Chamblin ordered that the defendants be allowed to proceed with predictive coding. Handwritten terms in the order allowed 60 days for processing and up to 60 more for production. A receiving party could still raise the completeness of the production or the ongoing use of predictive coding with the court. Counsel for one plaintiff signed the order as seen and objected to. The order gives no reasons and no finding on cost or accuracy, and the review had not run."}},"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":"The Circuit Court for Loudoun County, Virginia, let the Landow defendants use predictive coding in the Dulles Jet Center cases over objections","headline":"Virginia court lets defendants use *predictive coding* over objections"}},"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":["0eb69a79cc21962e0df7e6307e5ef41ca4fdee9c91000d26f6e6344ba6a7fe92"],"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":"Three hangars at the Dulles Jet Center in Loudoun County, Virginia, collapsed in a snowstorm in February 2010, and the lawsuits were consolidated in the county's circuit court. Other parties objected when the Landow defendants proposed predictive coding for their electronic files. In their memorandum, the defendants estimated that linear review of more than two million documents would take 20,000 hours and cost two million dollars. They claimed that predictive coding could find upwards of seventy-five percent of the potentially relevant documents at a fraction of the cost. On 23 April 2012 Judge James H. Chamblin ordered that the defendants be allowed to proceed with predictive coding. Handwritten terms in the order allowed 60 days for processing and up to 60 more for production. A receiving party could still raise the completeness of the production or the ongoing use of predictive coding with the court. Counsel for one plaintiff signed the order as seen and objected to. The order gives no reasons and no finding on cost or accuracy, and the review had not run.","replication":{"produced_by":["The defendants held an estimated 250 gigabytes of reviewable electronic files.","An attorney codes training documents until the tool stabilizes, and the tool then applies its model to the collection.","The defendants offered to give opposing counsel the training documents, apart from privileged documents and sensitive irrelevant ones."],"must_hold":["Processing finishes within 60 days, and production follows within a further 60 days.","A receiving party can still raise the completeness of the production with the court.","The coding goes on until the recall measured on samples reaches at least 75%."],"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":27,"reviewed":2,"reviewed_complete":2,"reviewed_partial":0,"record_mapped":25,"review_not_assessed":64,"not_assessed":0,"complete":false,"by_state":{"value_present":27,"not_reported":0,"unresolved":64,"not_assessed":0,"not_applicable":0,"withheld":0,"source_unavailable":0}}},"presentation_version":"5654a5b4ddce9d6ecca8181f27b1bc728152625a31dfc7ea648a9519d35244b9"}