{"id":"AIBD-0994","title":"A US court's e-discovery special master found that Huntsman's TAR review had already met his benchmark for a presumptively reasonable search","summary":"In October 2022 a US special master found that Huntsman's TAR review had met his benchmark for a reasonable search, with 9.1% responsive documents in its last two batches.","date_observed":"2022-10-21","date_basis":"source publication","date_precision":"day","benefit_status":"reported","source_collection":null,"source_entry":null,"account":"In a multidistrict antitrust case in the Western District of Pennsylvania, the defendants used search terms and technology-assisted review (TAR) to find documents for discovery. The plaintiffs moved to compel further TAR review. On 19 October 2022 E-Discovery Special Master James C. Francis IV recommended that Wanhua Chemical (America), Huntsman Corporation and Covestro resume their reviews. Each was to continue, presumptively, until the last two batches reviewed held no more than 10% responsive documents. He had understood that each company stopped while that share was materially greater than 10%. Huntsman's share was first given to him as 18%. On 21 October 2022 he reported that it was in fact 9.1%, a figure that the plaintiffs did not dispute. He found that Huntsman had already met his benchmark for a presumptively reasonable search and dropped the requirement for Huntsman. The district court adopted both reports on 7 November 2023. The supplemental report rests on a figure from a declaration filed in the case. It does not test the software, report recall or compare TAR with manual review.","category":"benefit created","unexpected":false,"purpose":"A vendor that the report does not name built the TAR software to find the documents that answer discovery requests, which reviewers then check in batches.","system":"TAR (technology-assisted review)","model_version":null,"developer":"Not named in the report","deployer":"Huntsman Corporation (defendant)","location":"Pittsburgh, United States","domain":"Legal services / e-discovery","segment":null,"benefit_type":"Improved Task Accuracy","work_activities":["4.A.2.a.2","4.A.1.a.1"],"taxonomy_note":"The special master found that the review met his benchmark for a reasonable search. He did not measure its accuracy against another method.","registry_ids":{},"ratings":[{"group":"organizational","depth":1,"reason":"Huntsman's review met the special master's benchmark for a reasonable search, so Huntsman did not have to resume it."}],"ai_role":{"status":"unassessed","statement":"The special master compared the share of responsive documents in Huntsman's last two batches with his 10% benchmark. He did not test the software or compare TAR with manual review. The report names the method only as TAR and does not describe the software or show that it learns from data."},"evidence":[{"kind":"court document","citation":"United States District Court for the Western District of Pennsylvania, E-Discovery Special Master James C. Francis IV (Ret.). In re Diisocyanates Antitrust Litigation, Master Docket Misc. No. 18-1001, MDL No. 2862, Supplemental Report and Recommendation (ECF No. 800), 21 October 2022, pp. 1-2. CourtListener RECAP copy.","title":"In re Diisocyanates Antitrust Litigation, Supplemental Report and Recommendation (ECF No. 800)","url":"https://storage.courtlistener.com/recap/gov.uscourts.pawd.250109/gov.uscourts.pawd.250109.800.0.pdf","date":"2022-10-21","written_by":"independent","quote":"Huntsman has already achieved the benchmark that I identified as representing a presumptively reasonable search, there is no longer a basis for"}],"replication":{"produced_by":["Huntsman reviewed the documents from its TAR process in batches and then halted the review.","The share of responsive documents in its last two batches was 9.1%."],"must_hold":["The last two batches reviewed contain no more than 10% responsive documents, the special master's benchmark for a presumptively reasonable search.","The parties may still argue that a review should stop sooner or run longer, depending on how important the documents in those batches are."],"echoes":[]},"paired_incident":null,"headline":"Huntsman's *TAR* review meets a special master's benchmark","metric":"9.1% responsive documents in its last two batches","comparator":{"against":"The special master's benchmark for a presumptively reasonable search, no more than 10% responsive documents in the last two batches reviewed","before":"no more than 10%","after":"9.1%","basis":"measured","quote":"Since Huntsman has already achieved the benchmark that I identified as representing a presumptively reasonable search, there is no longer a basis for requiring it to resume its TAR review.","url":"https://storage.courtlistener.com/recap/gov.uscourts.pawd.250109/gov.uscourts.pawd.250109.800.0.pdf"},"later":{"status":"litigated","date":"2023-11-07","note":"The plaintiffs filed limited objections to the 19 October 2022 report. 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