On February 18, 2014, the New York District Court issued an order in a gender discrimination class action, which among others, allowed the compelled party to manually review the documents resulting from an agreed-upon search term query. The Court considered the use of search terms to be a form of TAR. Since neither party agreed to produce documents without further human review, Defendant was not precluded from reviewing the documents before production.
More on Chen-Oster v. Goldman, Sachs & Co., Case No. 10 Civ. 6950, 2014 WL 716521 (S.D.N.Y. Feb. 18, 2014) is available at http://goldmangendercase.com/