Comparing GenAI to Machine Learning and Manual Review for eDiscovery

Gordon V. Cormack, Maura R. Grossman, Jeremy Pickens

Keeling et al. [Keeling2026Generative] report on a case study recently conducted by Redgrave LLP in which they assert that Relativity's Generative AI Review tool (aiR) achieved 88% recall while Relativity Assisted Learning (RAL), its machine-learning tool, achieved 64% recall. These results are not comparable because the methods employed have different objectives, because of inter-assessor disagreement, and because they represent different recall-precision and cost-benefit trade-offs. Our analysis of the Redgrave data indicates that, when these differences are taken into account, aiR and manual review are comparable. Furthermore, established machine-learning models employing Continuous Active Learning (CAL) show state-of-the-art effectiveness, and superior efficiency, when trained only on a sample of 2,000 first-pass-reviewer responsiveness determinations.