Valve Corporation v. Rothschild et al.
W.D. Washington · Feb 9, 2026
- Jurisdiction
- federal
- Court
- W.D. Washington
- Record ID
- valve-corporation-v-rothschild-et-al-2026-02-09
- Observed outcome
- The court issued an order to show cause requiring lead counsel to file a sworn declaration addressing the use of AI, the accuracy of corrected filings, and internal supervision protocols.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued an order to show cause requiring lead counsel to explain the presence of fabricated citations and quotations in their filings. Counsel must provide a sworn declaration addressing their use of AI tools, the accuracy of their corrected briefs, their internal supervision protocols for contract attorneys, and their future compliance measures to ensure the integrity of court submissions.
Outdated Advice: Overturned Case Law | Defendants relied on Mukhtar without acknowledging it was subsequently overruled by later Ninth Circuit authority; plaintiff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.
An open-letter apology does not moot a show-cause order; require pre-filing citation audits to avoid needing one.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Contract
- Trial
- Ordered To Show Cause
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued an order to show cause during pretrial evidentiary proceedings, following the identification of multiple citation and quotation errors in the defendants' filings.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Retain a matter-level record of source checks and corrections.