Lifetime Well LLC v. IBSpot.com Inc.
The case
Lifetime Well LLC v. IBSpot.com Inc., No. 25-5135 (E.D. Pa.), memorandum and order filed January 26, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-124-lifetime-well-v-ibspot.pdf`. Source URL: https://www.damiencharlotin.com/documents/1398/Lifetime_v._IBSpot_USA_26_January_2026.pdf
What happened
New York attorney Yen-Yi Anderson (appearing pro hac vice) and local counsel Jeffrey J. Goldin signed a motion to dismiss containing at least eight false case citation hallucinations generated by artificial intelligence. A new law clerk in Anderson's office had used Lexis+ AI and LexisNexis Protégé as her primary research tools without disclosing it; Anderson failed to catch the errors, and Goldin signed without reading or checking the case law. Both admitted the lapse.
The rule and the sanction
The court found both attorneys violated Federal Rule of Civil Procedure 11. Sanctions: Anderson was ordered to pay $4,000 from her personal funds to the City Bar Justice Center's Neighborhood Entrepreneur Law Project, with a cover letter enclosing the order, memorandum, and her firm's new AI policy, and to send copies of that cover letter to the judges and counsel in the two other known cases where the law clerk had used AI. Goldin received a non-monetary sanction: he must send a cover letter to the President of the Philadelphia Intellectual Property Lawyers Association enclosing the order, memorandum, and his AI policy, with a request that it be shared with the membership. No bar referrals were made.
How it could have been avoided
(a) Local counsel is not a rubber stamp: read and check every citation before signing another attorney's work. (b) Supervising attorneys must know what tools their staff use; undisclosed AI research must be surfaced by policy, not discovered by courts. (c) Firing the subordinate while admitting the lapse still leaves the signing attorney responsible; supervision and verification are nondelegable.