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the delivery of their services. The same attention that companies and their legaldepartments have given to increased efficiency by their outside counsel (albeit withmixed results according to a recent Altman Weil survey 2 which found that only fourpercent of chief legal officers are satisfied with how firms traditionally provide legalservices) is increasingly being focused on in-house legal departments.One of the trends in legal departments is to undergo a review of all legal departmentprocesses using the Lean Six Sigma methodology 3 which requires a team effort toimprove performance by systematically eliminating waste and inefficiencies. Theoriginal Six Sigma was developed by Motorola in the mid-1980s and is well knownlargely because Jack Welch made it central to his business strategy at General Electricin the mid-1990s. 4Although Six Sigma and Lean Six Sigma originally were focusedmore on manufacturing entities than service based entities, these concepts have morerecently been applied to service providers, including law firms and law departments.The focus on greater efficiencies through concepts like Six Sigma and Lean Six Sigmahas caused corporations to examine all of their operations, including the legaldepartment. One reason that improving the efficiencies of legal departments is soimportant is that 40 percent of the chief legal officers in the recent Altman Weil survey(see fn2) reported that they have recently shifted more legal work in-house that wasformerly sent to outside counsel. Thus, in-house efficiencies have become increasingly2 Altman Weil, 15 th Annual Chief Legal Officer Survey, 2014.3 George, Michael and Lawrence, Robert, Jr., LEAN SIX SIGMA Concepts Were First Published InLEAN SIX SIGMA: COMBINING SIX SIGMA WITH LEAN SPEED, 2002.4 See, What is Six Sigma, www.ge.com/en/company/companyinfo/quality/whatis.3