Amazon.com Inc. et al. v. Kathy Q. Hao et al.
W.D. Washington · Jun 15, 2026
What happened in this matter?
The court struck the defendant's motion to dismiss without prejudice and issued a formal warning. The judge declined to impose monetary sanctions at this time but explicitly cautioned that future filings containing fabricated, nonexistent, or misstated authorities could result in further sanctions, including monetary penalties or additional nonmonetary directives.
- Why the court cared
- The court applied the objective standard of Federal Rule of Civil Procedure 11, noting that pro se litigants who are licensed attorneys are held to the same standard of reasonable inquiry as other counsel. The court reasoned that reliance on AI-assisted research does not excuse the filing of unverified or fabricated authorities, which consume judicial resources and delay case progress.
- Why it matters now
- This case reinforces that licensed attorneys, even when appearing pro se, are strictly liable under Rule 11 for the accuracy of their filings. It confirms that reliance on generative AI is not a valid defense for submitting fabricated legal authorities.
Why this matter is tracked
In a trademark dispute, defendant Kathy Q. Hao, a licensed attorney appearing pro se, filed a motion to dismiss containing fabricated case law, nonexistent authorities, and misstated legal propositions. Amazon moved for an order to show cause regarding these defects. Hao acknowledged relying on artificial-intelligence-assisted research and failing to verify the accuracy of the cited authorities. The court held that Hao’s reliance on AI and her lack of federal litigation experience did not excuse her failure to meet the objective reasonableness standard required by Federal Rule of Civil Procedure 11. Consequently, the court struck the motion to dismiss without prejudice, allowed refiling, and issued a formal warning that future filings containing unverified or fabricated authorities may result in further sanctions.
This case reinforces that licensed attorneys, even when appearing pro se, are strictly liable under Rule 11 for the accuracy of their filings. It confirms that reliance on generative AI is not a valid defense for submitting fabricated legal authorities.
Record details
What the record establishes about AI use
Defendant acknowledged reliance on AI-assisted research.
The court resolved Amazon's motion for an order to show cause by striking the defendant's motion to dismiss (Dkt. 6) with leave to refile.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Cited nonexistent cases and fabricated authorities; Amazon identified multiple authorities that do not exist.
- False Quotes: Case Law | Paired real reporter citations with unrelated or nonexistent case names and attributed propositions to cases that do not support them.
- Misrepresented: Legal Norm | Misstated statutory and regulatory authorities and attributed legal propositions to authorities that do not support them.
Questions this record answers
- What happened in Amazon.com Inc. et al. v. Kathy Q. Hao et al.?
- The court struck the defendant's motion to dismiss without prejudice and issued a formal warning. The judge declined to impose monetary sanctions at this time but explicitly cautioned that future filings containing fabricated, nonexistent, or misstated authorities could result in further sanctions, including monetary penalties or additional nonmonetary directives.
- Why does Amazon.com Inc. et al. v. Kathy Q. Hao et al. matter for legal AI risk?
- This case reinforces that licensed attorneys, even when appearing pro se, are strictly liable under Rule 11 for the accuracy of their filings. It confirms that reliance on generative AI is not a valid defense for submitting fabricated legal authorities.
- What does the public record establish about Amazon.com Inc. et al. v. Kathy Q. Hao et al.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Amazon.com Inc. et al. v. Kathy Q. Hao et al. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.