East Coast hospital network culls 9.4M documents from FTC Second Request review

A large East Coast hospital and physician network had to respond to a U.S. FTC Second Request covering a multi-million-document corpus under tight deadlines. Reviewing the full population at that scale was not feasible within the required timeline.

With Consilio’s guidance, the client secured FTC agreement to use Email Threading and a TAR 2.0 Continuous Active Learning (CAL) workflow to limit the review population. Consilio helped document the TAR workflow, statistical sampling methodology, and reporting so regulators would accept the approach. Consilio Analytics was then applied across the corpus via email threading, file analysis, and TAR.

The team reduced the initial document population by 9.4 million documents. Email Threading removed a large volume of documents, file analysis removed a significant share, and the TAR workflow removed 4.3 million while achieving 86% recall. The client was able to meet tight timelines, lower review cost, and keep the production approach aligned with FTC expectations.

• Regulator-approved Email Threading plus TAR 2.0 CAL can cut Second Request review volume at multi-million-document scale without abandoning defensibility.
• Documenting sampling methodology and TAR reporting early helps secure FTC confidence in AI-assisted culling.
• Layering threading, file-type/junk analysis, and CAL produced complementary reductions totaling 9.4M documents.