Courts on AI / Discovery and AI-assisted review
Schulte v. LinkedIn Corp.
U.S. District Court for the Northern District of California · Federal district courts · CA · · No. 4:22-cv-00237-HSG-LB · order
On 2026-07-01, the Northern District of California resolves discovery disputes over LinkedIn’s use of Relativity aiR. The court permits search-string pre-culling before GenAI review and denies additional audit metrics, finding LinkedIn’s disclosures satisfied the interim ESI order absent a specific deficiency.
- Disposition
- The court denied plaintiffs’ requests to restrict LinkedIn’s Relativity aiR workflow and compel additional metrics.
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
On May 15, 2026, LinkedIn provided the plaintiffs with twenty-five search strings to be applied against LinkedIn’s custodial documents. At the same time, LinkedIn informed the plaintiffs that it would be using Relativity aiR, a GenAI review tool, “to assist in filtering out non-responsive documents.” On May 23, 2026, the plaintiffs requested more information about LinkedIn’s use of Relativity aiR. LinkedIn disclosed that “(1) there was no seed or training set used; (2) Relativity aiR is being used to make final responsiveness calls; and (3) quality control review is being conducted by human review of samples taken from each responsiveness type.” ... Courts have held that using search terms to pre-cull documents before providing them to technology-review platforms satisfies the reasonableness and proportionality standards of Rules 26(b) and 34(b)(2). E.g., Livingston v. City of Chicago, No. 16-cv-10156, 2020 WL 5253848, at *3 (N.D. Ill. Sep. 3, 2020); In re Biomet M2a Magnum Hip Implant Prods. Liab. Litig., No. 3:12-MD-2391, 2013 WL 1729682, at *2 (N.D. Ind. Apr. 18, 2013). The court finds the same here.
Authorities cited in the passage: Fed. R. Civ. P. 26(b) · Fed. R. Civ. P. 34(b)(2) · Livingston v. City of Chicago, No. 16-cv-10156, 2020 WL 5253848 (N.D. Ill. Sep. 3, 2020) · In re Biomet M2a Magnum Hip Implant Products Liability Litigation, No. 3:12-MD-2391, 2013 WL 1729682 (N.D. Ind. Apr. 18, 2013)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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