By Sam Ballingrud and Markus Funk ( November 27, 2017, 5:20 PM EST) -- The average computer user creates about 320 megabytes of data per day — the equivalent of approximately 24,000 pages of paper. For any corporation — no matter the size or life span — this means producing so much data that it can be expressed only in scientific notation. The only way to search such vast amounts of data at a reasonable cost and in a reasonable time frame is to search by keywords. And an investigating attorney's choice of key terms and search patterns reveals a significant amount about the nature and status of any internal investigation. However, what is useful to attorneys in internal investigations is also useful to adverse third parties. Attorneys conducting internal investigations frequently — and often without giving the topic much thought — turn over their search term lists to opposing counsel or to government enforcers. This, however, can be a mistake with long-lasting results, including waiver of applicable privileges (including subject-matter waiver). Attorneys conducting internal investigations must protect their client's interests by protecting such important information from improper and unnecessary disclosure....