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HSR Second Request Goes Remote

HSR Second Request Goes Remote (Case Study)

How a $20B Food Manufacturing Company Met a DOJ Deadline with a Virtual Team


A 20-billion-dollar global food manufacturing and processing titan sought to sell a division in an international transaction that triggered Department of Justice (DOJ) scrutiny and led to a comprehensive HSR Second Request. The corporation and its outside counsel needed millions of electronically stored records collected, processed, culled, analyzed, reviewed, and produced—all within 70 days. Data sources ranged from enterprise cloud systems to collaborative chat solutions and remote workers’ local resources. When the company reached out to BIA for help with this incredibly complex and time-sensitive process, our expert team went to work.


  1. From data collection to final production, the entire process had to be conducted remotely. Everyone was working remotely: custodians, IT professionals, the majority of the company’s internal resources, outside counsel, and most of the legal professionals working on the matter.
  2. The company had used multiple collaboration and communication applications during the years subject to review. This included Microsoft Teams, Skype (calls and chats), and other complex internal enterprise systems. All systems needed to be examined and any potentially responsive data collected, processed, and accurately reviewed and produced. While the eDiscovery industry has made significant strides in solutions for handling such collaboration data, any combination of such systems renders the entire process much more complex and challenging.  
  3. Our team had only 70 days to complete the process—from the first ESI collection to the last document production.


BIA’s solutions were remote enabled long before the COVID pandemic forced the world into remote work. When the need arose here, our people and systems immediately responded to support every need. BIA assembled an expert team to handle the entire workflow, and that team worked around the clock for 70 days to make sure our client met the DOJ deadline.

Our team worked closely with the client’s IT and Legal teams to identify, preserve, and collect all data needed to comply with the DOJ’s requests. As data was collected, it was processed, filtered, and culled for review quickly and accurately. We leveraged our powerful cloud-based and expandable-on-demand data processing platforms to grind through terabytes of data in short order.

BIA’s Second Request process protocols and workflows enabled that data to be swiftly loaded to the review platform on a rolling basis as data was collected. This empowered the attorney review team to start—and ultimately complete—the document review process more quickly.

To provide a document review process that was both rapid and highly accurate, BIA utilized multiple sophisticated machine learning artificial intelligent solutions—all integrated into the review platform. We leveraged Brainspace to assist the document review and QC teams. We created custom solutions to facilitate workflow requests that were not available in Relativity, Brainspace or H5 Matter Analytics directly.

By combining those analytics-based data reduction tools with our custom solutions, we quickly eliminated clearly non-responsive and junk data to focus on the truly important data. This helped our client control costs by ensuring that the attorney document review process wasn’t bogged down by irrelevant data. Our custom workflow utilizing H5MA reduced the hours typically spent on privilege log creation by at least half.

As the review team completed the review of the first data sets, BIA prepared rolling productions for delivery to the DOJ that met or exceeded the DOJ’s demanding production standards. Those rolling productions continued on a regular and routine basis throughout the process, proceeding in parallel with the continuing review process.


BIA experts guided the company through the process and assisted outside counsel in the effective, efficient, and defensible review and production of ESI resources without any significant additional costs.

The final productions were delivered to the DOJ just two days after the review process itself was completed, and the entire process was completed on time and on budget.

Once productions were completed, BIA continued to assist outside counsel with additional reporting and other functions throughout the remainder of the proceedings.

Download the Full Case Study.

Learn how a $20B food manufacturing company met a DOJ deadline for HSR Second Request review and production with the help of BIA’s remote team of eDiscovery experts.