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The recent predictive coding wars have led to a separate but related battle over how much information is appropriate to share—or to force a party to share—as part of the seed set and training process. One recent example is the much-litigated protocol for production of electronically stored information (ESI) in Moore v. Publicis Groupe,1 in which a federal court concluded that computer-assisted review was an appropriate means of determining relevant and discoverable documents for production. Addressing the e-discovery process more broadly, the court noted that, “[e]lectronic discovery requires cooperation between opposing counsel and transparency in all aspect of preservation and production of ESI.”2

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