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It will come as no surprise to anyone who has handled complex litigation during the past five years that the volume of electronically stored information that must be reviewed in the course of discovery can be staggering. It may be more surprising to learn that keyword search is not nearly as effective at identifying relevant information as many lawyers would like to believe. See David C. Blair and M.E. Maron, “An Evaluation of Retrieval Effectiveness for a Full-Text Document-Retrieval Sys.,” 28(3) Comm. of the ACM 289 (1985) (showing lawyers estimated their search had identified 75 percent of the relevant documents when only about 20 percent were found); Douglas W. Oard, et al., Overview of the TREC 2008 Legal Track (March 17, 2009), (showing Boolean search identified only 24 percent of the relevant documents); Stephen Tomlinson, et al., Overview of the 2007 TREC Legal Track (April 30, 2008), (showing Boolean search identified only 22 percent of the relevant documents).

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