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Résumé : Although it is well established that recall estimates are valid only when based on independent relevance assessments, and useful only to compare the relative effectiveness of competing methods, these conditions are seldom met when validating eDiscovery efforts in litigation. We present two unbiased validation strategies that embed blind relevance assessments into a technology-assisted review (TAR) process, so as to compare its recall to that which would have been achieved by exhaustive manual review. We illustrate the use of these strategies within the context of TAR occasioned by litigation over accounting practices preceding the collapse of a major insurance company.