Coronavirus Reporter Corp. v. Apple Inc.

Coronavirus Reporter Corp. v. Apple Inc., United States District Court for the Northern District of California, July 30, 2025, No. 24-cv-08660-EMC, Doc. 102. Judge Edward M. Chen. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-77-coronavirus-reporter-v-apple.pdf

Plaintiffs' counsel Keith Mathews admitted he used ChatGPT to generate in its entirety an exhibit (a petition seeking to end Apple's suppression of free speech and demanding the CEO's resignation) and submitted it to the court three times. Other motions contained hallucinated case citations and quotations. The court found these filings violated Rule 11(b)(2) and (3).

The court held sanctions warranted under Rule 11 and awarded defendant Apple the reasonable fees and costs incurred in connection with the litigation, with Apple to submit attorney declarations, time sheets, and a brief defining the recoverable hours and costs. Note: the order sets Apple's entitlement to fees; the dollar amount was to be fixed after Apple's submissions, so the candidate metadata's "$1" figure is incorrect and no final amount is stated in this order. Follow-on orders fixed the amount: a May 2026 order (Dkt. 113) approved Apple's $661,673.88 lodestar as reasonable, and an October 13, 2026 order (Dkt. 120) imposed a $25,000 sanction against Mathews personally, payable in $1,000 monthly installments beginning November 1, 2026.

Never file an AI-drafted document without reading and verifying every authority and factual assertion it contains. Filing the same unverified exhibit three times multiplied the exposure; withdraw and correct an AI-generated filing as soon as an error is suspected.