Whether you know it or not, defense was probably using TAR before you even filed your complaint. Litigation planning MUST cover TAR protocols. While the technology is very effective, and ILS has been at the forefront of its use in cases from DiSilva Moore and Actos on down the line, TAR can be applied to avoid categories of documents that Plaintiffs are entitled to receive. They often reflect the defense-oriented biases of the machine programmers bring to the system. When performed in a balanced manner, with Plaintiff participation, TAR can uncover the smoking guns and highly probative evidence that you’re after. ILS will help you get there.
 TAR refers to the broad subject of Technology Assisted Review. It has been called Predictive Coding, Continuous Active Learning, TAR 1, TAR 2, TAR 3, CAR or computer assisted learning, machine learning, etc. All these work through the same principle of finding relevance through computer driven algorithms that reflect the human decisions programming the machine learning mechanisms.