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A large manufacturer of consumer products invests in new technology to record, store and analyze customer service calls. A key feature of the technology is that it uses machine learning and other forms of artificial intelligence to help the company track features of its communications with its customers and improve the customer service system. After a few years of operation, the company collects tens of thousands of hours of audio data. The company is sued regarding its consumer practices, and the plaintiffs issue document requests seeking all communications between the company and its customers regarding certain products. The general counsel seeks advice on the company’s obligations to produce the stored audio data and how best to review the data to identify responsive communications while limiting the costs.