Law Firm Equipped with 35 Deposition Kits, At or Before DOJ Deadlines, for Massive Antitrust Investigation

Responding to a Fast-Moving Government Investigation, with a Merger on the Line

When two of the largest publishing companies in the country entered a merger deal, the Department of Justice (DOJ) reacted with a large anti-trust investigation. Pursuant to an HSR Second Request, the companies produced a combined six million documents to the DOJ. In response, the DOJ sought to depose 35 individuals within a few months’ time. This left outside counsel with just two months to prepare for the defense of a massive potential merger, including intensive preparation for all 35 depositions. To do so, they knew they would need to find every shred of relevant information hidden within those six million documents—as quickly as possible.

Executing a Plan for Better Legal Strategy

When the law firm reached out to Lighthouse for help, our agile search team of analytic, legal, and linguistic experts immediately got to work, consulting with counsel to understand the specifics of the investigation, as well as the case team’s initial strategy for response. Using this background, the Lighthouse team mapped out a information search plan leveraging advanced volume reduction technologies and linguistic search models, delivering:

• Comprehensive deposition kits for all 35 deponents. Each kit was scheduled to be delivered well ahead of the corresponding deposition date, and included summaries of Lighthouse experts’ findings and highlights of notable documents and facts, in order to give counsel adequate time to prepare for each deposition.  
• Key and relevant documents related to the DOJ’s anti-trust concerns and outside counsel’s defense strategies. These documents, provided on a rolling timeline, were uncovered by conducting two large scale data investigations: one to find all documents related to determining which publishers participated in or won the auctions, and another to find all documents necessary to facilitate the creation of an all-encompassing book auction timeline.

Given the legal and analytic expertise of our specialists, Lighthouse search results often uncovered new areas of importance for the case team. When the case team responded to this new information with urgent follow-up search requests (with results sometimes needed in 24 – 48 hours), our team also boosted efforts to provide the requested information.  

Powering Counsel with Knowledge—and Time

By partnering with Lighthouse, the case team stayed focused on preparing for depositions and crafting a response to the DOJ’s concerns to the merger, instead of conducting database searches and reviewing irrelevant or redundant documents.

In just two months, Lighthouse found and delivered the 4,100 documents the case team needed, out of an initial population of six million documents. This included creation and delivery of 35 deposition preparation kits, all documents related to the case team’s strategy for responding to the DOJ’s antitrust concerns (delivered on a rolling basis), and results of six ad hoc case team investigation requests. All deposition kit and derivative search deliveries met or exceeded counsel’s delivery deadline expectations.