Daniel Jaiyong An v. Archblock, Inc.
2024-0102-LWW
| Del. Ch. | Apr 4, 2025Background
- The petitioner, Daniel Jaiyong An, filed a motion to compel discovery from the respondent, Archblock, Inc., in the Delaware Court of Chancery.
- The motion included multiple inaccurate and fabricated legal citations, with some attributed quotes and authorities not existing in the cited cases or legal databases.
- The court suspected the use of generative artificial intelligence (GenAI) in preparing the motion, leading to inaccurate citations, likely due to "AI hallucinations."
- Delaware courts recognize the utility of GenAI but emphasize the necessity of accuracy and verification when submitting materials to the court.
- The respondent (defendant) flagged these inaccuracies, arguing that relying on false authorities wastes resources and undermines the legal system.
- The court ultimately denied the motion with prejudice and warned the petitioner of potential sanctions for any future failures to comply with court rules and citation accuracy requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has broad discretion over discovery | The court has broad discretion in resolving discovery disputes, citing Terramar | Motion cites fabricated/non-applicable precedents, not actual authority | Court rejects fabricated/incorrect citations |
| Application of discovery stays | Parties cannot unilaterally stay discovery (citing Deutsch, misquoted) | The motion invents authority; actual case does not support this proposition | Court finds no basis for plaintiff's claim |
| Interpretation of Rule 26 (scope of discovery) | Delaware courts construe discovery rules broadly (citing NCT Grp., misquoted) | Plaintiff used non-existent quotes and fabricated authority | Court holds citation is not supported |
| Use of GenAI in legal filings and potential sanctions | Use of GenAI is beneficial if accurate and cited properly | Deceptive filings from GenAI undermine process; sanctionable conduct | Denial of motion; warning of sanctions |
Key Cases Cited
- No cases with official reporter citations were cited or relied upon by the court for substantive holdings. The decision primarily addressed the misuse and fabrication of authority rather than precedent-based discovery rules.