Searching through large volumes of data is one of the biggest challenges for in-house counsel when trying to locate potentially responsive documents in discovery, according to an informal poll Wednesday during a legal webinar, “2015 Litigation Cost and E-Discovery Trends.”

And the second biggest challenge is closely related: developing criteria for determining which documents are relevant.

“Determining the criteria is a big obstacle,” said panelist Andrea D'Ambra, senior counsel at Norton Rose Fulbright, “because it can change over time. And different people, including the judge, can have a different definition of what is relevant.”