In EORHB, Inc. v. HOA Holdings LLC, No. 7409 (Del. Ch. Oct. 15, 2012), Vice Chancellor J. Travis Laster ordered the parties to implement predictive coding in their electronic discovery process or “show cause why this is not a case where predictive coding is the way to go.”  It appears that this is the first instance of a court sua sponte ordering parties to use predictive coding in discovery.  The case involved an indemnification dispute, which the court explained could “generate a huge amount of documents.”  For that reason, the court held that the parties could “benefit from some new technology use” rather than “burning lots of hours with people reviewing” documents.  The court further held that the parties should confer “about a single discovery provider that could be used to warehouse both sides’ documents,” or, if the parties could not agree, to “submit names to [the court] and I will pick one for you.”