Coronavirus Reporter Corporation v. Apple Inc.

What sanction did the court impose?

The Court found Rule 11 sanctions warranted against Plaintiffs and counsel Keith Mathews and ordered Apple to submit declarations and time sheets documenting reasonable attorney's fees and costs incurred as a direct result of the sanctionable conduct, with the fee award to be set after that submission. The Court denied Apple's separate requests to revoke Mathews' pro hac vice admission and to declare Plaintiffs, Dr. Jeffrey Isaacs, and Mathews vexatious litigants, holding that such relief required a properly noticed motion.

Why does Coronavirus Reporter Corporation v. Apple Inc. matter for law firms using AI?

The order is notable for two reasons a managing partner should track. First, the sanctioned attorney candidly disclosed that ChatGPT drafted a 20-page filed exhibit in roughly ten minutes and that his own review took under fifteen, framing it as a “legal experiment”; the Court treated that disclosure as direct evidence that no reasonable Rule 11 inquiry occurred. Second, the same response brief defending against sanctions itself contained a fabricated quotation, illustrating how AI-introduced citation defects tend to compound across successive filings once the verification habit breaks down.