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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Valve Corporation v. Rothschild et al.
W.D. Washington · Feb 9, 2026
WA / federalEditorial impact: mediumfake citationsfabricated quotesmisrepresented authoritycontract
Direct answer
What happened in this matter?
Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling. Outcome: Order to show cause. When warned about the issue, cousel apologised in an open letter to the Court.Later on, the Court issued a Show Cause Order (see here).
- Why the court cared
- Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling. || Fabricated: Case Law | Defendants cited a non-existent PacTool opinion and quoted text that does not exist in the case; plaintiff's counsel states the opinion does not exist and the quoted text is fabricated. || False Quotes: Case Law | Defendants quoted language attributed to Crow Tribe that is not contained in the opinion; plaintiff notes the case exists but the quoted text is fabricated. || False Quotes: Case Law | Defendants attributed a quotation to Cordis (Fed. Cir.) that does not appear in the opinion; plaintiff identifies the quote as fabricated. || False Quotes: Case Law | Defendants quoted Bilzerian for language about expert testimony creating an "aura of authority"—plaintiff states the quoted text does not appear in Bilzerian and the proposition is unsupported by that case. || False Quotes: Case Law | Defendants partially misquoted Primiano; plaintiff notes the quoted language is incorrect and provides the correct formulation from the case. || False Quotes: Case Law | Defendants attribute an “ipse dixit” quote to Micro Chem. plaintiff says the case exists but the quoted language is not found and the case does not support Defendants' broader proposition. || Fabricated: Case Law | Defendants cited an Amazon.com v. Personal Web Technologies opinion that plaintiff reports does not exist in the W.D. Wash.; plaintiff identifies the opinion as fabricated. || Fabricated: Case Law | Defendants cited Diamondback Industries v. Repeat Precision opinion and quoted a holding that plaintiff reports does not exist; plaintiff identifies the opinion/quotation as fabricated. || Misrepresented: Case Law | Defendants cited Marx & Co. but relied on a proposition the case does not address; plaintiff notes the case exists but was misapplied. || Misrepresented: Case Law | Defendants cited Bausch & Lomb but attributed a proposition about expert testimony admissibility that the case does not support; plaintiff characterizes this as a misrepresentation. || False Quotes: Case Law | Defendants cited Fortune Dynamic with a quoted passage not found in the opinion; plaintiff notes the case exists but the specific quoted language was not located in the decision.
- Why it matters now
- An open-letter apology does not moot a show-cause order; require pre-filing citation audits to avoid needing one.
Why this matter is tracked
Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling. Outcome: Order to show cause. When warned about the issue, cousel apologised in an open letter to the Court.Later on, the Court issued a Show Cause Order (see here).
Operational lesson
An open-letter apology does not moot a show-cause order; require pre-filing citation audits to avoid needing one.
Record details
WashingtonSingle-state evidence scope
CourtW.D. Washington
Jurisdictionfederal
Circuit9th Circuit
DateFeb 9, 2026
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeOrder to show cause
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Order to show cause
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
12 citation, quotation, or authority issues are recorded in the source dataset.
- Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling.
- Fabricated: Case Law | Defendants cited a non-existent PacTool opinion and quoted text that does not exist in the case; plaintiff's counsel states the opinion does not exist and the quoted text is fabricated.
- False Quotes: Case Law | Defendants quoted language attributed to Crow Tribe that is not contained in the opinion; plaintiff notes the case exists but the quoted text is fabricated.
- False Quotes: Case Law | Defendants attributed a quotation to Cordis (Fed. Cir.) that does not appear in the opinion; plaintiff identifies the quote as fabricated.
- False Quotes: Case Law | Defendants quoted Bilzerian for language about expert testimony creating an "aura of authority"—plaintiff states the quoted text does not appear in Bilzerian and the proposition is unsupported by that case.
- False Quotes: Case Law | Defendants partially misquoted Primiano; plaintiff notes the quoted language is incorrect and provides the correct formulation from the case.
- False Quotes: Case Law | Defendants attribute an “ipse dixit” quote to Micro Chem. plaintiff says the case exists but the quoted language is not found and the case does not support Defendants' broader proposition.
- Fabricated: Case Law | Defendants cited an Amazon.com v. Personal Web Technologies opinion that plaintiff reports does not exist in the W.D. Wash.; plaintiff identifies the opinion as fabricated.
Show 4 additional discrepancies
- Fabricated: Case Law | Defendants cited Diamondback Industries v. Repeat Precision opinion and quoted a holding that plaintiff reports does not exist; plaintiff identifies the opinion/quotation as fabricated.
- Misrepresented: Case Law | Defendants cited Marx & Co. but relied on a proposition the case does not address; plaintiff notes the case exists but was misapplied.
- Misrepresented: Case Law | Defendants cited Bausch & Lomb but attributed a proposition about expert testimony admissibility that the case does not support; plaintiff characterizes this as a misrepresentation.
- False Quotes: Case Law | Defendants cited Fortune Dynamic with a quoted passage not found in the opinion; plaintiff notes the case exists but the specific quoted language was not located in the decision.
Questions this record answers
- What happened in Valve Corporation v. Rothschild et al.?
- Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff notes the failure to acknowledge overruling. Outcome: Order to show cause. When warned about the issue, cousel apologised in an open letter to the Court.Later on, the Court issued a Show Cause Order (see here).
- Why does Valve Corporation v. Rothschild et al. matter for legal AI risk?
- An open-letter apology does not moot a show-cause order; require pre-filing citation audits to avoid needing one.
- What does the public record establish about Valve Corporation v. Rothschild et al.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Valve Corporation v. Rothschild 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.