Big Data 3: Structured Data In Discovery And Class Certification (Electronic Discovery & Information Governance - Tip Of The Month)

Scenario

A large e-commerce company is facing a putative class action lawsuit in which the plaintiffs allege that the company posted misleading and deceptive price comparisons on its website and that, as a result, the plaintiffs overpaid for the products that they purchased from the company. The plaintiffs have just moved for class certification, and they have asked for all of the company's pricing and sales transactions data, which are stored on the company's proprietary multi-terabyte relational databases. The company has asked counsel for advice on how to identify, preserve, collect, process and produce this data in responding to the plaintiffs' written discovery and how to offensively access and use this data in the company's own efforts to defeat class certification. To complicate matters, the data contains confidential financial and proprietary business information as well as private customer information such as customer addresses, telephone numbers and credit