He’s not a real Leprechaun!


Catelas is a relatively new company so I thought I would say a little about our CEO and Founder, Eddie Cogan.

Raised in County Cork, Ireland, Eddie spent the first half of his working life in Europe, sprinkled with some time in Japan. He then moved to Boston, USA where he now resides. He is an accomplished engineer who graduated into sales (note the slight bias) by virtue of being assigned to new, impossible projects that had to be sold internally or  to partners or customers… apart from his natural “gift of the gab”.

Eddie was instrumental in building Autonomy’s early eDiscovery business, but in a moment of self-flagellation and madness decided to start his own company.  He is not a real leprechaun (as far as I know), but hopefully he will find his pot of gold.

If you know Eddie drop him a note and say hi…or reply to this post and I will pass on your best wishes.

Is there a gaping hole in the EDRM?


Firstly, with all due respect to Mr George Socha, I am not about to poke a stick at the validity of the much hallowed ERDM. The eDiscovery business continues to be well guided by it, but…. are we missing something?

Three years ago when I entered the world of eDiscovery, which by the way was at LegalTech 2009, a term Early Case Assessment (ECA) was all the rage. As someone who had come from the world of Information Security this made a lot of sense to me. I asked a lot of questions and while ECA meant many things to different people, for the most part it was a process for ‘getting one’s ducks in a row’   (getting organized) before the humdrum of following Mr Socha’s ERDM took place.

Very soon ECA was part of every vendor’s offering. In fact vendors re-invented themselves around ECA with many variations such as “we will pre-review your data using the assigned keywords and only charge you for the culled data”. But is something wrong here?

ECA seems to have become a cost assessment or financial calculator – ie “using these keywords we will cull down 300gig to 50gig in a linear fashion so that we achieve a manageable dataset to review”. It sounds terribly mathematical to me and somewhat contrived.

My observation is that the “intelligence” of ECA has been lost. A critical component of ECA should be to help attorney’s quickly assess the case, but I mean strategically assess it, not tactically. Understand if this is a case that could seriously expose the company. Get under the hood and understand whether you need a new engine or an oil change…. before you start negotiating how much it will cost to fix!

At Catelas we use the term “Early Case Intelligence” which does just that, we get under the hood. Maybe it will catch on, but we hope it fills a gap at the start of a case that answers the strategic questions (defend or settle) rather than simply the tactical one’s.

Let me know what you think.

How corrupt are your foreign business operations?


Welcome to the first of the Catelas blog posts. We have been working with companies on FCPA compliance for the past 3 years and continue to be astounded at just ‘how in the dark’ most Compliance Officers are with respect to their overseas business operations.

While the lure of doing business in countries like China, Russia and Indonesia is certainly great, the risks that come with it are equally so. Our experience is that most companies do a pretty good job at vetting potential partners, 3rd parties and individuals when they first enter a new country (through fairly rigorous background checks), but apart from re-inforcing policies and codes of conduct, that is pretty much where it ends.

The full-time, round the clock monitoring of these partners (or individuals) to uncover potential bribery or corruption is clearly cost-prohibitive and not usually practical. And most of the monitoring is focused on the financials, ie expense reports to try to uncover unreasonable or unwarranted spending.

That is why Catelas has approached the problem from a totally different perspective. If we could analyze the daily communications of a company (both inside and outside the company) and focus on those high-risk countries, partners and individuals, then we could uncover potential risks to the company, before potential FCPA infractions occur.

Tall order? Sure. And costly too? Perhaps. So we have developed a fast, effective and non-disruptive way to audit and report high-risk relationships, typically at 6 monthly intervals. Like an MRI, Catelas is able to provide Compliance Officers peace-of-mind with respect to potential FCPA violations. We identify ‘who is doing business with whom’, providing 360° profiles for companies to help them understand which countries, partners or individuals pose the highest risk based on the day-to-day communication patterns inside and outside the company.