Pyrrho Invs. Ltd. v. MWB Property Ltd.  EWHC 256 (Ch.) is reported to be the first instance of an English court approving the use of predictive coding in aid of discovery. Citing Moore v. Publicis Groupe, 287 F.R.D. 182 (S.D.N.Y. 2012) (No. 11-1279), the British Chancery Court approved the use of predictive coding after noting the “enormous” expense of manually reviewing over three million electronic documents in the case. The Chancery Court stressed that the purpose of predictive coding and computer-assisted review was not to “replac[e] humans,” but was “the review method to result in higher recall and higher precision than another review method, at cost proportionate to the value of the case.” The court held other jurisdictions’ positive experiences with predictive coding, the consistency with which a computer would apply criteria, the cost of computer-assisted as compared to a manual review, the value of the claims at issue, the long interval available to the parties to address any unsatisfactory results from predictive coding before the scheduled trial date, and both parties’ consent to use predictive coding supported its decision.