Bridgestone Americas v. International Business Machines Corp.

2014 WL 4923014 (2014)

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Bridgestone Americas v. International Business Machines Corp.

United States District Court for the Middle District of Tennessee
2014 WL 4923014 (2014)

RW

Facts

Bridgestone Americas, Inc. (Bridgestone) (plaintiff) and International Business Machines Corporation (IBM) (defendant) were engaged in litigation. The federal court’s electronic-discovery (e-discovery) order stipulated that the parties would use keyword searches to screen over two million documents of potentially relevant electronically stored information (ESI). Following the initial keyword sweep of data, Bridgestone moved for the court’s permission to analyze the search results with predictive coding, a form of technology-assisted review (TAR). IBM had already manually reviewed over one-third of the search results and objected that it was unfair to change screening methods so late in e-discovery.

Rule of Law

Issue

Holding and Reasoning (Brown, J.)

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