Five million documents needed to be collected, reviewed and produced in 10 days.


An AmLaw100 firm was retained by their client, a multi-national Fortune 500 company, to help complete a response to a Hart-Scott-Rodino Second Request* from the Department of Justice. D4 was engaged by the firm to support the Second Request eDiscovery process.


The proposed merger could not go forward until the second request was completed, pressuring the team to collect, review and produce the responsive materials as quickly as possible. Five million documents were collected (1.6TB of data) and the firm had 10 days until production. To make it even more complicated, this included translation and review of foreign language documents.


D4’s Data Operations Group and Discovery Engineering Team worked with the firm’s staff to identify large chunks of data that were clearly not responsive. The D4 team was also able to identify patterns of data that were not responsive and removed them from the review set. Over 1.6TB of data was reduced by over 40% before processing, utilizing advanced data analysis and reduction techniques. 

D4 was then able to process and image potentially responsive data for deeper review in Relativity. D4 deployed the necessary operational and project management resources that were required to support such a large data set with a ten-day turnaround.


The law firm was able to meet the DOJ production specifications and finished in ten days, thereby meeting the DOJ deadlines, as well as saving the client time and money. The DOJ made no material objections to the ultimate document production and the transaction successfully closed as planned.

* In United States antitrust law, a second request (under the Hart-Scott-Rodino Antitrust Improvements Act of 1976) is a discovery procedure by which the Federal Trade Commission and the Antitrust Division of the Department of Justice investigate corporate mergers and acquisitions which may have anti-competitive consequences. A typical second request asks to gather information about the sales, facilities, assets, and structure of the businesses which are party to the transaction.

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