Epiq culls down data set for Hart Scott Rodino Second Request


The client had to fulfill a Hart Scott Rodino Second Request, requiring production of responsive documents identified from a collection of more than 5 terabytes of documents. All the data had to be analyzed and reviewed so documents relevant to the merger could be delivered to the Department of Justice in 45 days.


Epiq started by forensically preserving all data and then systematically culled down the data set. By using process- and technology-based data minimization techniques, Epiq was able to reduce the data set by more than 96 percent prior to document review.

Based on its extensive experience with Second Requests, Epiq knew that it would likely be able to reduce the data set substantially by creating directory trees and interviewing custodians first and then further by applying keyword search techniques. Our understanding of techniques for managing redundant data allowed for a quicker and more efficient document review.


Epiq started by creating directory trees and – along with outside counsel – interviewed custodians to identify folders where data might reside, resulting in a reduction to 600 gigabytes. Epiq then applied standard deduplication, keyword searching and other data minimization techniques to cull the data set down to 300 gigabytes, which were processed for native review. Since 300 gigabytes still represents more than a million documents, Epiq then ran nearduplicate identification and thread compression technology, reducing the amount of email to be reviewed by 40 percent.

Epiq used its proprietary processing engine as well as best-in-breed solutions, applying kCura’s Relativity as a review platform and Equivio to compress email threads and identify near-duplicates.


The Epiq data-reduction techniques reduced the cost of document review by more than $200,000 – and allowed the client to produce the responsive documents by deadline.



view all right


view all right

Legalweek New York


© 2021 Epiq. All rights reserved.

By continuing to browse and accepting this banner, you consent to the storing of first and third-party cookies on your device to enhance site navigation, analyze site usage, and assist in Epiq’s marketing efforts. Read more on our cookie notice.