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This paper critically evaluates claims comparing Generative AI, traditional machine learning, and manual review in eDiscovery, arguing that disparate methodologies render direct recall comparisons invalid. The authors demonstrate that established machine learning models utilizing Continuous Active Learning achieve state-of-the-art efficiency with minimal training data when contextual factors are properly accounted for. This analysis provides essential clarity on the actual performance trade-offs between different AI approaches in legal document review workflows.
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Comparing GenAI to Machine Learning and Manual Review for eDiscovery

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arXiv:2610.16925v1 Announce Type: cross Abstract: 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.

Abstract: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.

Machine Learning (cs.LG); Artificial Intelligence (cs.AI); Information Retrieval (cs.IR)

arXiv:2610.16925 [cs.LG]

(or arXiv:2610.16925v1 [cs.LG] for this version)

https://doi.org/10.48550/arXiv.2610.16925 Focus to learn more arXiv-issued DOI via DataCite (pending registration)

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