LiveVideo.AI Corp v. Redstone

What sanction did the court impose?

The court granted the defendants' motion for sanctions in full. It held that the struck motions were "entirely meritless": filed in violation of the filing injunction, each apparently "drafted by AI" with "hallucinated, non-existent quotations" and "no real authority," and repeating arguments the court had already rejected. It inferred bad faith from their meritless nature and from the earlier finding that the action was brought to harass the defendants, and concluded that an award of attorneys' fees was warranted under 28 U.S.C. § 1927 and the court's inherent power. Applying the lodestar method, it found the defense firm's rates and 62 hours spent opposing the struck motions reasonable, noting that LiveVideo had itself conceded the rates fit a challenge to an eight-billion-dollar merger. LiveVideo and Constants were ordered to pay $85,056 in attorneys' fees and costs within 21 days, and Constants was again referred to the Grievance Committee of the Southern District of New York. The order does not apportion the award among the three grounds; apparent AI drafting is one of them, alongside the filing-injunction violation and the repeated arguments (slip op. at 6, 9-10).

Why does LiveVideo.AI Corp v. Redstone matter for law firms using AI?

Judge Ho’s order is a second-round sanction. The first round, in September 2025, adopted a magistrate judge’s recommendation, imposed a $10,000 penalty, referred counsel to the Grievance Committee, and enjoined LiveVideo from filing further motions for affirmative relief without leave. LiveVideo kept filing. The court struck the new motions as violations of the injunction, issued an order to show cause regarding contempt, declined to award sanctions at that time, and later received the defendants’ fee motion, which it granted in full.

The AI findings are central to the merits analysis rather than a side note. The court described nearly all of the plaintiff’s motions as bearing “the hallmarks of artificial intelligence (‘AI’) fabrication,” listing three indicators: hallucinated cases, formatting unchanged from AI output, and “remnants of prompts that the drafter declined to delete.” In finding the struck motions meritless, it relied on their apparent AI drafting and “hallucinated, non-existent quotations” alongside the injunction violation and the repetition of rejected arguments, citing Park v. Kim. The court added that LiveVideo’s opposition to the sanctions motion “again appears to be drafted entirely by AI.”

The award itself follows the ordinary fee-shifting framework. The court applied the lodestar method, accepted the defense rates because LiveVideo had conceded they fit a challenge to a multibillion-dollar merger, and found 62 hours reasonable for responding to thirteen docket entries of briefing and exhibits. The payment order runs against both the corporate plaintiff and its counsel, and the order refers Constants to the Grievance Committee a second time.