February 27, 2018


1 p.m. ET

Register Here

A primer on Magistrate Grossman’s new TAR validation protocol

Whether you are doing traditional linear review, keyword filtering or TAR, the end goal is to produce a reasonable number of relevant documents. Perfection isn’t required but sufficient recall—the percentage of relevant documents produced—is the sine qua non. Validation is the term we use for the process to show you have reached that goal.

Special Master Maura Grossman recently issued a landmark order crafting a new type of validation protocol, one that applies to every form of review. In Re Broiler Chicken Antitrust Litigation (Jan. 3, 2018, N.D. Ill). We wrote about it first in TAR for Smart Chickens. Michelle Lange recently wrote about this groundbreaking approach to validation for ACEDs as well.

How does this new protocol work? Join us for an in-depth look at Master’s Grossman’s intriguing approach to a difficult problem. Our goal will be to make it simple to understand and easy to follow.

In this webinar, we will cover:
  • Guidelines for pre-search culling, targeting and domain filtering.
  • Comments on the use of search terms with TAR/CAL.
  • Required TAR/CAL disclosures and challenges.
  • Keyword search requirements and staging procedures.
  • A new validation process adding independent QC which applies to all review methods.

Master Grossman’s order is important not just for the parties in the Broiler Chicken Antitrust Litigation. Rather, this is the first comprehensive validation order that meets statistical needs as well as common sense. If you plan to use keyword search or any form of TAR in your next big case, you can expect to be required to meet some form of this groundbreaking validation order.


Thomas C. Gricks III | Managing Director, Professional Services | Catalyst
Thomas Gricks 150

Tom is a managing director at Catalyst and a licensed attorney in Pennsylvania. Before recently joining Catalyst, he was a general commercial litigator for 23 years. He practiced before both federal and state courts across the United States, and, in addition to Pennsylvania, is admitted to practice in a number of federal jurisdictions, including the Supreme Court. For the past several years, Tom has devoted a substantial portion of his practice to e-discovery, with a particular emphasis on TAR. He argued the Global Aerospace case before the Circuit Court in Loudoun County, Virginia, which is the first case to permit the use of TAR over the objection of the opposing party.

John Tredennick | Founder and CEO | Catalyst
Andrew Bye

John Tredennick is the CEO and founder of Catalyst Repository Systems, which designs, builds and runs the world's fastest and most powerful software platform for complex e-discovery, regulatory investigations and compliance. A former trial lawyer and litigation partner with a large national law firm (20+ years), John has written or edited five books and countless articles on litigation and technology issues and has spoken before legal-technology audiences in five continents. Recently, The American Lawyer named him one of the top six e-discovery trail blazers in its issue on the “Top 50 Big Law Innovators of the Last 50 Years.” He also served as chair of the American Bar Association’s Law Practice Management Section and was editor-in-chief of its flagship magazine Law Practice and the founder and editor of its webzine Law Practice Today.


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