Drew Lewis, General Counsel and Vice President of Innovation at Paragon, and I discuss the Lutzeier v. Citigroup Inc., 2015 U.S. Dist. LEXIS 11727, 20-21 (E.D. Mo. Feb. 2, 2015), case, where a motion to compel additional search terms was denied based on proportionality. Drew and I discuss how "search concepts" should be the focus in litigation and finding what is necessary to prove one's case.