Scaling Review with AI for FTC Compliance

Background

The client faced a high-stakes Hart Scott Rodino (HSR) Second Request with tight compliance deadlines under FTC oversight:

• 7.5M documents (7.8TB) were collected in 2 phases from 28 custodians collected across email, collaboration platforms, mobile data, and hard copy sources.
• Differentiated responsiveness standards between groups of custodians, requiring tailored review strategies.
• The matter was re-opened months later and additional documents requested.

The Lighthouse Approach

The team implemented both IQ Review and IQ Priv, combining AI analysis with disciplined managed review execution. Key elements included:

• AI-supported relevance review and a team of 30 contract attorneys for documents that required eyes-on review
• Privilege review, privilege log and names legend automation via AI
• AI image analysis for visual and scanned content

Two separate AI models were trained to address differing responsiveness criteria across custodial groups, ensuring precision without sacrificing defensibility.

Results

Lighthouse successfully processed 7.5M total documents across both collections. Because our AI models remain largely stable even with new documents, analysis of the second phase of collection was able to start immediately.

LighthouseIQ powered analysis meant that only 2,500 contract review hours were needed in total. Using AI insights, our contract review attorneys maintained high review velocity across responsiveness, privilege, and PII review streams.

The approach delivered FTC-ready defensibility under close regulatory scrutiny while enabling rapid adaptation to an evolving regulatory scope. Through expert coordination across legal, technical, and review teams, the engagement delivered predictable, consistent performance even under compressed timelines and shifting requirements.

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