In 2012, Judge Peck’s ruling allowing for technology-assisted review (TAR) in Da Silva Moore v. Publicis Group changed the discovery landscape, allowing for cost savings as long as e-discovery is done reasonably. In March 2015, Justice Fullam in Ireland brought TAR outside the U.S. for the first time, allowing for predictive coding in Irish Bank Resolution Corporation Limited & Ors v. Sean Quinn & Ors.

However, despite increased TAR recognition in two recent U.S. cases, including Rio Tinto Plc v. Vale S.A., TAR had seemed to be confined to those two countries. But now, the UK – the world’s second largest discovery market – is open to TAR usage.

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