In Rio Tinto PLC v. Vale S.A., No. 14 Civ. 3042, 2015 WL 872294 (S.D.N.Y. Mar. 3, 2015), Magistrate Judge Peck, who has previously authored widely-cited opinions on computer-assisted document review, issued a new opinion on that subject.  Judge Peck wrote that “it is now black letter law that where the producing party wants to utilize TAR [technology assisted review] for document review, courts will permit it.”  Judge Peck collected several examples of recent federal cases approving various forms of TAR.  Judge Peck noted that one “issue that remains open” in this area is “how transparent and cooperative the parties need to be with respect to the seed or training set(s),” which are used to “teach” a computer system which documents are relevant.  Judge Peck suggested that this issue can be handled in different ways, depending on the nature of the case and the type of review protocol used.  Judge Peck stressed, however, that “it is inappropriate to hold TAR to a higher standard than keywords or manual review” because “doing so discourages parties from using TAR for fear of spending more in motion practice than the savings from using TAR for review.”