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Sep 2018 - Oct 2019


Tyler Reed is a senior trial paralegal at Callahan and Blaine, a law firm based out of Santa Ana, California. As a trial paralegal of almost a decade, he prepares technical exhibits and demonstrations in court to help his attorney win cases.

The Sacramento Bee is one of California’s oldest newspapers. For decades, they had misclassified their newspaper delivery carriers as independent contractors. While the carriers had signed contracts with the Bee and were managed, trained, and supervised by them, they had little or no right to negotiate the terms of their contract. This meant that the newspaper avoided paying taxes and other employee benefits.

Tyler’s firm represented the carriers in a class-action lawsuit against The Bee to seek mileage reimbursements - and the carriers won in 2014.


But the legal journey was not over yet. While the carriers had won, the next important task was to ensure the carriers were paid fairly for their mileage costs.

The unusual task Tyler faced was to calculate as accurately as possible how much The Bee owed the carriers in unpaid salary and mileage costs in the years 2005 to 2009, over a decade ago.

“The Sacramento Bee is one of California’s more prominent newspapers with hundreds of thousands of subscribers all over the state, so the amount of data we were dealing with is huge,” said Tyler.

“Although we had a list of addresses that each carrier was supposed to deliver newspapers to, we did not know how much mileage was incurred by the carrier in making these deliveries.”

To add to the complexity of the problem, the subscriber list saw changes from day to day. The route and number of newspaper deliveries the carriers made changed as well.

“We knew about Afi Labs because they are one of the few software consulting companies that specialize in logistics, and we asked them to come up with a solution to calculate the damages for us,” said Tyler.


Afi Labs broke down the complex problem and framed it mathematically so that the team of programmers could crack the case with code.

First, starting with a flat text file of all of Sacramento Bee’s subscribers, the start and end dates of their subscription and their addresses, they used the Google maps API to plot a map of all the subscribers that had newspapers delivered to by a given carrier on a specific day.

Next, they ran a custom-built route optimization algorithm to find the shortest route that the carrier could have taken to deliver those newspapers. The mileage was calculated in this manner.

Finally, they applied an approved IRS (Internal Revenue Service) mileage rate for each carrier and summed up the total amount owed over all the days that each carrier delivered newspapers.

Of course, Tyler was relieved. “If we had to do this manually, it would have taken a team of analysts years to put 1 million routes together! Instead, Afi Labs was able to build the route optimization engine and run the analysis in less than four months, just in time for our trial date.”

Including testimonies, depositions and background research, the whole process took about 8 months.


“Afian, the CEO of Afi Labs, was fun to work with. He clearly knew his stuff and applied his knowledge of route optimization to a complex problem,” said Tyler.

The data had to be impeccable. In addition to the map and routing features that allowed lawyers to check calculations, Afi Labs also built a searchable database of each carrier, the mileage costs incurred and the addresses they visited each day.

“In presenting our mileage calculation to the court, we had to make sure that there were no mistakes,” Tyler said. “It was super helpful to be able to look at specific carriers and fix data points, such as bad addresses, and add or remove carriers from the final calculation as needed.”

Thanks to Afi Labs and Afian’s testimony, the lawyers were able to firmly make the case that the optimal route calculated using the engine was a conservative estimate of the mileage each carrier actually incurred.

“Anyway, more often than not, the carriers would probably use a longer route,” Tyler shared.

The proposed settlement that the carriers and The Bees arrived at included $7 million for mileage reimbursement.


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