Delphoria Learning
Certificate Program · 2026 Edition
Vol. I  ·  Rev. 03
A Delphoria Learning Certificate · 8 Modules

The Practitioner's EDRM.

EDRM from start to finish — collection through case law, without vendor bias or fluff.

Cohort
Start Date
Format
Delphoria Learning, LLC
A Delphoria Systems company  ·  Philadelphia, PA
Clarity, Delivered.
The Practitioner's EDRM
Course Overview
Welcome

A senior practitioner's
walk through the EDRM.

You already know the doctrine. This course teaches you how the work actually gets done — from the first custodial interview to the last privilege log entry, and everything the model draws in between. You'll leave able to scope, evaluate, and defend an eDiscovery matter — and pick the right tool and vendor for each stage — in plain English.

Delphoria doesn't run your collections or your processing. We help you evaluate the tools and vendors that do — so the workflow is defensible, the invoice is fair, and the story you tell a court holds up. Eight modules move through Collection, Processing, Loading, Review, Analytics, Production, Privilege Log, and the case law shaping how counsel is expected to use these tools — and, increasingly, AI. Each module pairs a lecture with a hands-on exercise on a live-fire matter scenario. No vendor bias. No hype. Just what works, what's defensible, and what actually improves outcomes.

What this course is (and isn't)
Delphoria isn't a vendor. We don't run collections, host review platforms, or process your data. We teach you to evaluate the people who do \u2014 to pick the right tool for the matter, hold the vendor to the SOW, and defend the workflow if a court asks. Transparency isn't a slogan here \u2014 it's policy.

At a Glance

Course Code
DLC-EDRM-101
Modules
8  ·  delivered weekly
Total Time
20 contact hours + ~10 hrs practice work
Delivery
Hybrid — live cohort + self-paced labs
Audience
Attorneys, paralegals, ops, law students
Prereqs
None. Curiosity helps.
CLE Credit
Up to 20 hrs (subject to state approval)
Certification
Delphoria Certificate of Completion
Cohort Size
18 seats — kept small on purpose
Cost
$1,495 · academic pricing available
Clarity, Delivered.
02
The Practitioner's EDRM
Contents
Contents

The Course, mapped to the model.

The EDRM — Where Each Module Lands Info Governance → Presentation
MOD 01
Collection
Cell, email, laptop, WhatsApp, chat, socials, network shares
MOD 02
Processing
Natives → structured, global de-dup, embedded objects
MOD 03
Loading
Templates that work in Relativity, Reveal, anywhere
MOD 04
Review
TAR 1, TAR 2, GenAI summary — and their risks
MOD 05
Analytics
Conceptual, contextual, generative — with a budget
MOD 06
Production
Responsive + privilege-hold logic, OCR, redactions
MOD 07
Privilege Log
Fields, populations, email-threading implications
MOD 08
Case Law
Rulings that shape how you use the tools — and AI
EDRM 1
EDRM 2
EDRM 3
EDRM 4
EDRM 4
EDRM 5
EDRM 5
Presentation
Course Modules
01
CollectionsAll data types, all sources, one unique ID that follows the doc through to the Delphoria Platform dashboard.
p. 04
02
ProcessingFrom natives to structured data — with a RelOne exceptions report you can actually read.
p. 06
03
LoadingTemplates that work in Relativity, Reveal, and everyone else — because the environment dictates the template.
p. 08
04
ReviewTAR 1 vs TAR 2 vs Generative AI — statistics, risks, and what doesn't belong in the workflow.
p. 09
05
AnalyticsConceptual, contextual, generative — where each earns its cost and where it doesn't.
p. 11
06
ProductionBuilding responsive searches, excluding privilege, OCR for redactions, metadata implications.
p. 12
07
Privilege LogFields, populations, and how email-threading choices reshape what appears on the log.
p. 13
08
American Case Law & AI in DiscoveryRulings, grouped by topic, that shape how counsel is expected to use these tools.
p. 14
Appendices
A
Assessment & CertificateWeighting, rubrics, CLE reporting, certificate issuance.
p. 16
B
Policies & AcknowledgementAttendance, integrity, materials use, signature.
p. 17
Clarity, Delivered.
03
Module 01 — Collections
EDRM · Identification & Collection
Module01
2.5 contact hours
Live lecture + guided lab
Reading: ~45 min
Module 01

Collections — every source, one identifier.

If a custodian used it to communicate, someone can collect it — your job is to know who, with what tool, and how to prove it was done right.

Collections is where defensibility is either built or broken — and it's rarely built by the lawyer running the matter. This module walks through every meaningful data source you're likely to encounter — from a company-issued laptop to a personal cell to a WhatsApp thread on a device you can barely unlock — and the tools your vendors will reach for on each. You'll leave with a Word document of the metadata fields output by each source, a working sense of which vendors specialize where, and the ability to speak to opposing counsel about any of it without hedging.

Learning Objectives

  • Identify appropriate collection tools per source type (mobile, cloud mail, endpoint, IM, network share, social) — and evaluate the vendors who run them.
  • Interpret the metadata each source produces — and what's missing.
  • Describe how a Unique Collection ID (Delphoria's recommended scheme) follows a document from collection through to the Delphoria Platform dashboard.
  • Draft a defensible collection protocol you can hand to a vendor and hold them to.

Topics Covered

  • Cell & tablet — physical, logical, file-system, iCloud/Google backups
  • Corporate email — M365, Google Workspace, on-prem Exchange
  • Endpoints — Windows, macOS, encrypted volumes, deleted-file recovery
  • Messaging — WhatsApp, Signal, iMessage, SMS/MMS
  • Collaboration — Teams, Slack, Zoom chat, Webex
  • Social — LinkedIn, X, Facebook, Instagram DMs
  • Network shares, SharePoint, OneDrive, Box, Dropbox, S3
  • Metadata deliverable format (Word doc) & the source-to-field map
Delphoria Unique-ID Lifecycle — the scheme we recommend
One identifier. Six stages. Zero orphaned documents. Your vendors implement it — you enforce it.
Format:  DLP-{matter}-{custodian}-{source}-{seq}
Stage 01
Collection
Vendor stamps UID at first-touch, before hashing
Stage 02
Processing
Preserved through natives → structured
Stage 03
Loading
Written to a first-class field, not a comment
Stage 04
Review
Filters, batching, sampling all key off UID
Stage 05
Production
Carried through Bates + on the load file
Stage 06
Delphoria Platform
Roll-ups by custodian, source, matter, cost
Why it matters: when a partner asks "where did this document come from and what's it cost me?" — the answer is a single query, not a two-week reconciliation project.
Module 01 · Collections
04
Module 01 — Collections
Exercise & Reading

Hands-On Exercise · Lab 01

"You've been asked to oversee a collection from a departing GC — laptop, corporate email, personal iPhone, and a Signal thread the compliance team just learned about. Two vendors have quoted the work."

  1. Draft the collection protocol you'll hold the vendor to — tool per source, chain of custody, custodian instructions.
  2. Draft the custodian-facing script for the Signal-thread ask. Take a breath — we've heard worse.
  3. Specify the Unique-ID format the vendor must apply at collection (per p.4).
  4. Map the Word-doc metadata deliverable to fields the review tool will need, and put it in the SOW.

Recommended Reading

  • EDRM — Identification & Collection frameworkedrm.net
  • Sedona Conference — Primer on Social Media, 2nd Ed.Sedona
  • FRCP 26(f) — Meet-and-Confer checklistUSC
  • NIST SP 800-101r1 — Guidelines on Mobile Device ForensicsNIST
  • Zubulake IV — preservation obligationsSDNY 2003
  • Delphoria — Collection Metadata Field Reference (course handout)DLC

Deliverables from this Module

  • Metadata reference (Word) — one row per source, mapping every field output by the collection tool with plain-English descriptions.
  • Collection protocol (template) — vendor-ready, editable, with the Delphoria UID scheme pre-populated.
  • Custodian interview script — with room for you to add matter-specific probes.
  • Delphoria Platform field map — the fields that feed the executive dashboard downstream.
Instructor Note
Bring the messiest matter you've inherited. If you don't have one, we do. "We accidentally removed every redaction in the production set" is not, in fact, the worst story we've heard — but it's a good one to open with.

Assessment for this module: Lab 01 protocol (pass/fail on defensibility checklist) + a 6-question quiz on metadata-source mapping.

Module 01 · Collections
05
Module 02 — Processing
EDRM · Processing
Module02
2.5 contact hours
Lecture + RelOne report walkthrough
Reading: ~40 min
Module 02

Processing — from files you know to data you can query.

Natives on the left. Structured data on the right. Everything worth defending — and every invoice worth scrutinizing — happens in the middle.

"Processing" is the least glamorous, most consequential step in the model — and it's the one you're most likely to hand to a vendor and forget about. Don't. This module makes it visual: the .msg, .xlsx, .pdf, and .zip files a custodian recognizes become rows in a database the review platform can filter, sort, and search. You'll learn how global de-duplication actually works across custodians, why embedded objects require care, and how to read a processing report (we use RelOne as the example) — including the exceptions you can push a vendor to remediate versus the ones you can't.

Natives · Familiar files

What the custodian handed you.

.msg.eml.pst .xlsx.docx.pdf .pptx.zip.rar .txt.csv.png .mp4.wav.json
Structured · Fields you can query

What the review tool sees.

DocIDDLP-2401-JS-M365-000123
CustodianSanders, J.
DateSent2025-11-04 09:12:07 UTC
Hash MD5a9c3…f21e
Family1 parent · 3 attachments
Text"Attached please find…"

Learning Objectives

  • Explain the natives-to-structured transformation to a client without a whiteboard.
  • Distinguish custodian-level de-duplication from global de-duplication and the cost implications.
  • Read a processing report (RelOne, Nuix, LAW) and triage exceptions.
  • Decide which exceptions are worth pushing back on the vendor to remediate — and which aren't.

Topics Covered

  • File-type identification, MIME sniffing, container extraction
  • Text extraction & OCR — when to run it upstream vs. downstream
  • Global de-duplication logic & the "who saw it first?" question
  • Embedded objects — images-in-Word, spreadsheets-in-email
  • Password-protected files: cracking, custodian re-ask, exclusion
  • Encrypted volumes, corrupt containers, zero-byte files
  • Time-zone normalization & the DST landmines
  • Processing metrics: input GB → output docs, cull ratios
Sample RelOne Exception — read live in class
"14,203 items processed · 12,981 loaded · 1,022 exceptions. Of those: 612 password-protected (remediable), 208 corrupt containers (partial remediation), 121 zero-byte, 81 unsupported types." You'll leave able to look at that block and know which numbers to fight for and which to write off.
Module 02 · Processing
06
Module 02 — Processing
Exercise & Reading

Hands-On Exercise · Lab 02

"Vendor sent over a RelOne processing report on a 480 GB collection. You have one hour with the client on the phone. What do you tell them — and what do you tell the vendor?"

  1. Triage the exceptions worksheet. Flag which the vendor must remediate, which you'll defer, which you'll abandon.
  2. Calculate the cull ratio and translate it into review-hour projections.
  3. Draft the client-facing summary — three paragraphs, no jargon.
  4. Identify two custodians whose data quality warrants a re-collection ask (and who pays for it).

Recommended Reading

  • Sedona Conference — Commentary on Defensible DispositionSedona
  • EDRM — Processing Standardsedrm.net
  • Grossman & Cormack — Technology-Assisted Review chapters on inputsJOLT
  • Relativity — Processing Report field referenceRelativity Docs
  • Delphoria — Exceptions Triage Cheat Sheet (course handout)DLC

Deliverables from this Module

  • Annotated RelOne report — with your triage notes and remediation asks.
  • Client-facing summary — the "three paragraphs, no jargon" version.
  • Global vs. custodian-dedup comparison — same corpus, both approaches, cost impact.
Common Misconception
"Processing" is not "loading." Processing turns files into fielded data. Loading (Module 03) is what puts that fielded data into the review environment. Vendors sometimes conflate the two on invoices — fair is fair, but read the invoice.

Assessment for this module: Lab 02 triage worksheet (rubric-graded) + a 5-question quiz on de-duplication logic.

Module 02 · Processing
07
Module 03 — Loading
EDRM · Processing → Review handoff
Module03
2.0 contact hours
Lecture + template workshop
Reading: ~30 min
Module 03

Loading — one template, any vendor.

The environment picks the template. The template shouldn't pick the vendor.

Loading is where processed data meets the review platform. The mechanics look different in every tool — Relativity, Reveal, Everlaw, Nuix Discover — but the underlying decisions are the same: which fields land in the tool, how they're typed, what the family relationships look like, and how the Unique-ID stays intact through the handoff. Delphoria maintains a vendor-agnostic template reference you can adapt, hand to any hosting provider, and expect a clean load in return.

Learning Objectives

  • Describe the difference between a load file, an overlay, and a production load.
  • Explain why the review-environment shapes the template — not the other way around.
  • Adapt the Delphoria vendor-agnostic template and use it to spec loads into two different platforms.
  • Recognize a load that "worked but didn't."

Topics Covered

  • .DAT, .OPT, .LFP — what each file does, and when
  • Field mapping, data types, encoding, delimiters
  • Family relationships & the parent/attachment integrity check
  • Loading into Relativity — RDC, Integration Points, RelOne workflows
  • Loading into Reveal — the differences that matter
  • Overlay strategy — coding, redactions, work-product carry-through
  • The Delphoria vendor-agnostic template reference: what's in it, why
  • Sanity checks a paralegal can run in fifteen minutes

Hands-On Exercise · Lab 03

"Same processed corpus. Different vendors quoted wildly different load fees. Why?"

  1. Compare two vendor SOWs against the Delphoria template reference. Identify the friction points that inflate cost.
  2. Walk through a mock load spec for a Relativity workspace and a Reveal workspace. Diff the field lists.
  3. Draft a one-page load-file spec you could send to a new vendor tomorrow.

Recommended Reading

  • EDRM — Load File standard specificationedrm.net
  • Relativity — Load File GuideRelativity Docs
  • Reveal — Data Ingest referenceReveal

Delphoria Handouts

  • Vendor-Agnostic Load Template — Excel, editableDLC
  • Field-Mapping Worksheet — for the environment intakeDLC
  • Sanity-Check Checklist — 15-minute verify after every loadDLC
Module 03 · Loading
08
Module 04 — Review
EDRM · Review
Module04
3.0 contact hours
Lecture + TAR statistics workshop
Reading: ~60 min
Module 04

Review — TAR 1, TAR 2, or "just ask the model."

Used well, these tools create leverage. Used poorly, margins erode.

This is the module that changes how you talk to opposing counsel. You'll leave able to defend a TAR protocol, run the statistical sampling that supports it, explain the trade-offs of Generative AI summarization, and — critically — identify the documents that should never enter a machine-learning workflow because their text is bad, their length is wrong, or their content will poison the model.

Axis TAR 1 · Predictive Coding TAR 2 · Continuous Active Learning Generative AI Summary
How it learns Trained on a stable seed set, then applied to the whole corpus once. Model retrains continuously as reviewers code — surfaces likely-relevant next. Doesn't "learn" per matter — LLM applies a prompt across documents.
Best on Static, well-defined corpora. Long timelines. Rich subject-matter expert time. Most modern reviews. Reviewer time is the scarce input. Summarization, first-pass triage, translated content, deposition prep.
Statistics Control-set F1, recall/precision at cutoff — defensible with proper sampling. Elusion/richness sampling at end — defensible, less front-loaded work. Hallucination rate + human spot-check — no accepted statistical standard yet.
Cost shape Heavy upfront (SME + control set), light back-end. Even burn — pay per reviewer hour and per prediction cycle. Per-document token cost + spot-check labor. Cheap at small scale.
Do NOT use on Small corpora (< ~10k docs), heterogeneous file types, low-text content. Corpora with badly extracted text or missing custodian metadata. Documents with encrypted/redacted regions, spreadsheets, images without OCR, poisoned prompts.
Risk profile Front-loaded — a bad seed set is expensive to unwind. Steadier — coding drift is the failure mode. Novel — hallucination, prompt injection, model-version drift.

Delphoria posture: use the workflow the corpus and the case can support — and be able to show your work. Transparency isn't a slogan here — it's policy.

Module 04 · Review
09
Module 04 — Review
Objectives, Exercise, Reading

Learning Objectives

  • Explain TAR 1, TAR 2, and Generative AI summarization to a client and to a court.
  • Design a sampling protocol that will hold up in a meet-and-confer.
  • Identify documents that should be routed out of ML workflows.
  • Calculate and communicate recall, precision, and elusion in plain English.

Topics Covered

  • Control sets, seed sets, richness estimates
  • Continuous Active Learning mechanics & stopping criteria
  • Prompt design & guardrails for Generative summary
  • Documents to exclude: bad OCR, oversized, undersized, spreadsheets, media
  • Reviewer training, quality control, second-pass workflows
  • Privileged & sensitive-data routing during first pass

Hands-On Exercise · Lab 04

"Opposing counsel wants your TAR protocol before you've picked one. What do you send?"

  1. Given a corpus profile (size, richness estimate, file-type mix) — choose TAR 1, TAR 2, or hybrid. Defend it in one page.
  2. Draft the exclusion criteria for a GenAI summarization pass on the same corpus.
  3. Compute the sample size you'll need to demonstrate recall of 0.80 at 95% confidence.

Recommended Reading

  • Da Silva Moore v. Publicis GroupeSDNY 2012
  • Rio Tinto v. Vale S.A.SDNY 2015
  • Grossman & Cormack — Evaluation of ML in eDiscoveryJOLT
  • Sedona Conference — TAR Case Law PrimerSedona

Delphoria Handouts

  • Sampling Calculator — ExcelDLC
  • GenAI Exclusion Rules — one-pagerDLC
  • TAR Protocol Boilerplate — editableDLC
The stakes
A defensible workflow that produces the right documents at half the cost is worth a great deal more than a "cutting-edge" workflow you can't explain. Context always matters.
Module 04 · Review
10
Module 05 — Analytics
EDRM · Review
Module05
2.5 contact hours
Lecture + tool comparison
Reading: ~40 min
Module 05

Analytics — conceptual, contextual, generative.

The right analytic on the wrong corpus is a very expensive graph.

Analytics is where the review environment stops being a database and starts being an argument. This module dissects three families — conceptual (clustering, near-dupes, email threading), contextual (concept search, communication analytics, sentiment), and generative (LLM-based summarization, entity extraction, Q&A). You'll leave able to size each one to a matter, quote what it costs, and know when to walk away.

Learning Objectives

  • Distinguish conceptual, contextual, and generative analytics — and their pricing models.
  • Estimate a break-even document-count for each family.
  • Explain how vendors charge for AI-enabled searches vs. regex vs. concept queries.
  • Recommend an analytics stack for a matter of a given size and budget.

Topics Covered

  • Near-duplicate detection & email threading
  • Concept clustering & taxonomy tools
  • Communication analytics — the "who talked to whom" map
  • Entity extraction, PII/PHI discovery
  • Generative Q&A over the corpus — costs, guardrails, drift
  • Regex vs. AI-enabled search: when each earns its keep
  • Vendor pricing patterns — per-doc, per-GB, per-query, per-model-call

Hands-On Exercise · Lab 05

"120,000-doc corpus. Fixed $75k budget for analytics. Build a stack."

  1. Choose the two analytics you'd deploy first. Justify against corpus profile.
  2. Model the run cost using two vendor pricing sheets you'll receive in class.
  3. Identify the point at which one analytic becomes cost-prohibitive.

Recommended Reading

  • Sedona Conference — Commentary on Search & RetrievalSedona
  • Relativity — Analytics profile pricing structureRelativity
  • Reveal / Brainspace — Concept search technical primerReveal

Delphoria Handouts

  • Analytics Break-Even CalculatorDLC
  • Vendor Pricing Cross-Reference (Q1 2026)DLC
Module 05 · Analytics
11
Module 06 — Production
EDRM · Production
Module06
2.5 contact hours
Lecture + production build workshop
Reading: ~40 min
Module 06

Production — responsive in, privilege out, redactions readable.

The set that leaves your door is the set opposing counsel gets to argue about. Get it right.

Production searches are boolean logic in a suit and tie: pull the responsive population, exclude anything on a privilege withhold, layer redactions where warranted, and hand it over in a format the receiving party can actually open. This module also covers OCR strategy for redacted documents (yes — after redaction, not before), metadata redaction, and the downstream effects on email threading that show up on the privilege log the following week.

Learning Objectives

  • Author a production search that produces responsive, non-privileged documents on the first try.
  • Build a redaction workflow that survives QC.
  • Explain metadata redaction implications for downstream threading.
  • Specify production format (image + text + native + load file) per protective order.

Topics Covered

  • Responsive-set logic: field-based, tag-based, family-based
  • Privilege-hold exclusion & the "should-be-privileged-but-isn't-tagged" problem
  • Redaction workflows — endorsement, layers, QC
  • OCR after redaction — why order matters
  • Metadata redaction: fields, formulas, tracked changes
  • Email-threading implications when parent/child metadata is redacted
  • Production formats: TIFF+text+native, PDF, near-native
  • Bates numbering, endorsements, protective-order legends

Hands-On Exercise · Lab 06

"Opposing counsel wants a rolling production of ~4,000 docs by Friday. Half need redactions. Two are attachments to privileged parents."

  1. Draft the production search — responsive AND NOT privilege-withhold.
  2. Write the QC pass that catches the "attachment to a privileged parent" case.
  3. Specify the redaction workflow including OCR ordering.
  4. Draft the cover letter — three sentences.

Recommended Reading

  • FRCP 34 & 26(f) — production form & meet-and-conferUSC
  • Sedona Conference — Cooperation ProclamationSedona
  • Aguilar v. ICE — form of productionSDNY 2008

Delphoria Handouts

  • Production Spec Template — editableDLC
  • Redaction QC ChecklistDLC
Module 06 · Production
12
Module 07 — Privilege Log
EDRM · Production
Module07
2.0 contact hours
Lecture + threaded-log build
Reading: ~30 min
Module 07

Privilege Log — fields, populations, and the thread problem.

The log is a document. Draft it like one.

The privilege log is where an opponent decides whether to file a motion. This module walks through the fields most jurisdictions expect, the populations you actually need to log versus the ones you can categorically claim, and the substantive impact of email-threading choices — because how you threaded the review population dictates what a "single privileged communication" even means on the log.

Learning Objectives

  • Enumerate the fields expected on a privilege log in federal & leading state venues.
  • Distinguish document-by-document logs, categorical logs, and metadata logs.
  • Explain how threading approach (inclusive email vs. all-emails) reshapes the log.
  • Draft descriptions that assert privilege without waiving it.

Topics Covered

  • Standard fields: Bates, date, author, recipient(s), cc/bcc, subject, description, privilege type
  • Metadata-only logs vs. narrative-description logs
  • Categorical logs — when they're accepted, how to defend
  • Email-threading approaches and what appears on the log for each
  • Withheld vs. redacted — logging obligations for each
  • Attachment logging when the parent is privileged
  • Common description pitfalls that trigger challenges

Hands-On Exercise · Lab 07

"Same 300 privileged emails. Two threading approaches. Two privilege logs. Compare."

  1. Build the log under an "all-emails" approach — count entries.
  2. Build the log under an "inclusive-emails-only" approach — count entries.
  3. Draft the meet-and-confer paragraph proposing the approach you'd recommend.

Recommended Reading

  • FRCP 26(b)(5) — claim of privilegeUSC
  • Sedona Conference — Commentary on Privilege LogsSedona
  • Local rules — SDNY, N.D. Cal., D. Del. (representative)Local

Delphoria Handouts

  • Privilege Log Field ReferenceDLC
  • Description Language Bank — approved phrasingDLC
Module 07 · Privilege Log
13
Module 08 — Case Law & AI
The Rulings That Shape the Practice
Module08
3.0 contact hours
Case reading + moot discussion
Reading: ~90 min
Module 08

American case law on eDiscovery & AI.

The cases that decided what "reasonable" means when the discovery is digital — and, increasingly, generated.

This module surveys the case law that has actually shaped how attorneys are expected to use discovery tools and, more recently, AI. The cases are grouped by the doctrine they moved. Read them in the order presented; each group builds on the previous. You'll leave with a working sense of what a court will accept, what will draw sanctions, and where the AI questions are still open.

Proportionality & ScopeGroup A · 4 cases
Zubulake v. UBS Warburg (I & III)
2003
Cost-shifting framework — accessibility of data, marginal utility, proportionality baseline.
Rowe Entm't v. William Morris Agency
2002
Early eight-factor cost-shifting test that Zubulake refined; still cited for framing.
Chen-Oster v. Goldman Sachs
2012
Proportionality applied to search-term negotiation; parties must justify volume asks.
Oracle Am. v. Google (proportionality orders)
2015
Modern proportionality after 2015 FRCP amendments; scope tied to case value.
Preservation & SanctionsGroup B · 4 cases
Zubulake IV & V
2003–04
Preservation obligations trigger & litigation-hold doctrine — foundational.
Pension Comm. v. Banc of America
2010
Gross negligence framework — later narrowed but historically pivotal.
Klipsch Group v. ePRO E-Commerce
2018
Sanctions for evasive collection & discovery misconduct — cost-of-remedy allowed.
GN Netcom v. Plantronics
2016
$3M sanction & adverse-inference for intentional email deletion — a Rule 37(e) landmark.
TAR & Predictive CodingGroup C · 4 cases
Da Silva Moore v. Publicis Groupe
2012
First judicial approval of predictive coding — Judge Peck's opinion is required reading.
Rio Tinto plc v. Vale S.A.
2015
Judge Peck: TAR is "acceptable" and often preferred — cooperation over compulsion.
Hyles v. New York City
2016
Court will not force a producing party to use TAR — party choice controls.
In re Broiler Chicken Antitrust
2018
Detailed TAR validation protocol adopted — a modern template for stipulations.
Module 08 · Case Law & AI
14
Module 08 — Case Law & AI
Privilege · AI · Assessment
Privilege, Waiver & ClawbackGroup D · 3 cases
Victor Stanley v. Creative Pipe
2008
Keyword search alone was inadequate to protect privilege — waiver where methodology failed.
Mt. Hawley Ins. v. Felman Prod.
2010
FRE 502(b) reasonableness — clawback protection depends on demonstrated process.
FTC v. Boehringer Ingelheim
2016
Categorical privilege logs accepted where narrative logs would be disproportionate.
AI in Legal PracticeGroup E · 4 cases & orders
Mata v. Avianca
2023
The ChatGPT fake-citations sanction — Rule 11 duty to verify AI output.
Park v. Kim
2024
Second Circuit affirms sanctions for AI-fabricated citations in a brief.
Standing Orders on Generative AI (N.D. Tex., D.D.C., et al.)
2023–25
Court-by-court disclosure and certification requirements for AI use in filings.
Kohls v. Ellison & downstream AI-evidence orders
2024–25
Authentication and admissibility questions when the evidence is AI-generated.
Modern Communications & Ephemeral DataGroup F · 3 cases
Waymo v. Uber
2018
Ephemeral-messaging preservation duties (Wickr / auto-delete features).
Doe LS 340 v. Uber Techs.
2023
Slack/collaboration platform preservation & production expectations.
SEC — off-channel communications settlements
2022–24
Regulatory-driven preservation obligations for WhatsApp/Signal in financial services.
How this module is taught
Cases are assigned by group across the two lecture blocks. Each cohort argues one Group C or Group E case as a moot to the rest of the class. Praise is nice. Criticism is useful.

Hands-On Exercise · Lab 08

"You're drafting a discovery protocol post-Mata. What do you write, and what do you refuse to write?"

  1. Draft an AI-use disclosure clause suitable for a federal filing.
  2. Draft the internal certification workflow that supports it.
  3. Identify two matter types where you would decline to use generative AI at all.
Module 08 · Case Law & AI
15
Appendix A
Assessment & Certificate
Appendix A

Assessment & Certificate.

Certification is earned, not attended. You'll be graded on the lab deliverables — the tangible artifacts you'd hand to a client — and short quizzes that check your working vocabulary. There is no final exam. There is a capstone protocol.

Grading Weight

ComponentWhat it looks likeWeight
Module Labs (01–08)Rubric-graded practical deliverables — one per module.60%
Module QuizzesShort vocabulary + concept checks after each module.15%
Capstone ProtocolDraft a full EDRM protocol for a matter of your choosing.20%
Cohort ParticipationMoot arguments & peer review in Module 08.5%

CLE Credit

This program is designed for up to 20 hours of CLE credit, including at least 1 hour of ethics (Module 08). Actual credit is subject to your jurisdiction's approval. Delphoria Learning will provide the accreditation paperwork; you file with your bar. Fair is fair.

Delphoria Certificate of Completion

Participants who complete all eight modules and earn ≥ 80% overall receive a numbered Delphoria Certificate of Completion, issued digitally and verifiable via the Delphoria registry. Recipients may use the "DLC-EDRM 2026" credential on résumés, LinkedIn, and firm bios.

Retake Policy
Missed a module? Take it with the next cohort at no additional cost. If we don't give you a receipt, it's free.
Appendix A · Assessment
16
Appendix B
Policies & Acknowledgement
Appendix B

Policies & Acknowledgement.

Attendance

Live cohort sessions are the core of the program. Two absences are permitted; a third requires cohort transfer. Recordings are provided for makeup but do not substitute for the lab-day exercises.

Academic Integrity

Lab deliverables must be your own. You may consult firm playbooks, prior work product, and AI tools — but you must disclose AI assistance on the cover page of any deliverable that used it. See Module 08 for why this matters.

Materials Use

Delphoria templates, checklists, and reference documents are licensed to you for internal firm use. Redistribution beyond your firm requires written permission. White-labeled versions are available for firm-wide adoption.

Accessibility & Accommodations

Reach out before day one. We accommodate what we can — and we're transparent about what we can't. Transparency isn't a slogan here — it's policy.

Get In Touch

Delphoria Guarantee
If, after Module 03, this isn't the course for you — we'll refund the balance and part on good terms. Data in the cloud, prices on the ground, panic nowhere to be found.

Participant Acknowledgement

I have read the syllabus for The Practitioner's EDRM: A Delphoria Learning Certificate. I understand the assessment structure, the CLE-credit process, and the policies above.

Participant Name
Signature
Firm / Institution
Date
© 2026 Delphoria Systems, LLC · Delphoria Learning is a Delphoria Systems company · Philadelphia, PA
Clarity, Delivered.
Appendix B · Policies
17