Bow Tie Law Law Blog looks at them. Check it out. Key graf: "The Court made what some would consider a surprising statement: [A]
clawback order can protect Defendants against a claim of waiver, such
that Defendants need no longer bear the cost of reviewing the ESI for
responsiveness and privilege. In re Coventry Healthcare, Inc., at *16. As such, the Defendants failed to show undue burden in producing electronically stored information."