IP Law Daily, AINews—E.D. Pa.: New York lead counsel and Philadelphia sponsor sanctioned for filing AI-generated citations, (Jan 27, 2026)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

The attorneys submitted AI-generated case laws without verification in the motion to dismiss a trademark infringement suit.

A federal judge in the Eastern District of Pennsylvania sanctioned two attorneys, one based in New York and the other local to Philadelphia, for violating Rule 11 of the Federal Rules of Civil Procedure by submitting a motion to dismiss that contained multiple false citations generated by artificial intelligence (AI). The court imposed a $4,000 monetary penalty on New York attorney Yen-Yi Anderson, directing her to pay the amount from personal funds to a legal nonprofit in New York. The court also ordered non-monetary sanctions against both Anderson and local counsel Jeffrey J. Goldin, requiring them to circulate the court’s opinion and their updated AI-use policies to relevant legal organizations and stakeholders (Lifetime Well LLC v. Ibspot.Com Inc., No. 2:25-cv-05135-MAK (E.D. Pa. Jan. 26, 2026)).

Background. The sanctions stemmed from a trademark and copyright infringement lawsuit filed by Lifetime Well LLC, a manufacturer of hearing aids, against IBSpot.com Inc., a New York-based online retailer. Lifetime Well sent IBSpot a cease-and-desist notice on July 29, 2025, accusing it of selling its hearing aids without authorization. After IBSpot failed to respond to the complaint filed in the Eastern District of Pennsylvania, the court entered a default judgment against the company on October 8, 2025. IBSpot retained Goldin, a member of the local bar, who secured the pro hac vice admission of Anderson on October 27, 2025. The court vacated the default judgment shortly thereafter and allowed IBSpot to file its response. On November 4, 2025, Anderson and Goldin jointly submitted a motion to dismiss on IBSpot’s behalf, signed and filed by Goldin. Upon review, the court discovered that the brief included at least eight citations that were either non-existent, misquoted, or drawn from inapposite jurisdictions.

Court’s opinion. The court's legal analysis centered on whether the attorneys violated Federal Rule of Civil Procedure 11(b), which requires attorneys to certify that any filing is based on a reasonable inquiry into the facts and the law. The court found that both Anderson and Goldin violated the Rule, with Anderson bearing primary responsibility as the drafting attorney. She admitted that a new law clerk at her firm had used Lexis+ AI and other tools to prepare the brief and had provided a spreadsheet of citations that were later flagged as 100% AI-generated by AI detectors. However, Anderson failed to personally verify any of the citations before signing the brief and instead relied on the law clerk’s assurances. The court emphasized that this was a nondelegable duty under Rule 11, and Anderson’s failure to fulfil it constituted a sanctionable breach.

Quoting Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023), the court reiterated that “a fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law.” It underscored the point made in Wadsworth v. Walmart Inc., 348 F.R.D. 489, 495–96 (D. Wyo. 2025), that an attorney cannot delegate their Rule 11 duties to a subordinate, and that “blind reliance on another attorney can be an improper delegation of this duty.” The court held that by signing the motion without verifying the authorities, Anderson personally certified the filing and was accountable for its accuracy.

Attorney Goldin’s conduct was also found deficient under Rule 11. While he did not draft the motion, he signed and filed it using his electronic credentials, thereby certifying that he had reviewed and approved its contents. The court held that Goldin’s reliance on Anderson’s work product, without performing even a basic due diligence review of the cited case law, fell short of his responsibilities as local counsel. Citing Wharton v. Superintendent Graterford SCI, 95 F.4th 140, 147–48 (3d Cir. 2024), the court noted that Rule 11 sanctions can be imposed based on negligence alone and that attorneys are required to demonstrate objective knowledge or belief that a filing is well-grounded in fact and law.

Despite finding a Rule 11 violation, the court exercised leniency in determining the scope of sanctions. It noted that Anderson’s initial response, terminating the law clerk, misplaced accountability and reflected a failure of supervision. Although Anderson later implemented a zero-tolerance AI policy, the court criticized her for not taking corrective action sooner when opposing counsel had flagged an inaccurate quote in the motion. The court concluded that both monetary and non-monetary sanctions were necessary to achieve Rule 11’s deterrent purpose. It ordered Anderson to pay $4,000 to the City Bar Justice Center’s Neighborhood Entrepreneur Law Project and to circulate the court’s memorandum and her firm’s new AI-use policy to relevant bar associations and judges involved in other matters where the same law clerk had used AI.

For Goldin, the court imposed only a non-monetary sanction, given his prompt acceptance of responsibility, completion of AI ethics training, and the implementation of new internal review procedures. He was directed to send the court’s opinion and his firm’s AI policy to the Philadelphia Intellectual Property Lawyers Association and request its circulation among members.

Finally, the court warned attorneys practicing in the district that “submissions containing unverified authority divert limited resources from other litigants” and emphasized that the attorney’s oath requires rigorous diligence. The ruling joins a growing body of federal decisions that address the misuse of AI in litigation and clarify that while AI tools may assist in legal research, they cannot replace an attorney’s obligation to ensure the accuracy of legal citations.

The Case is No. 2:25-cv-05135-MAK.

Judge: Kearney, M.

Attorneys: Howard N. Shipley (Gordon Rees Scully Mansukhani LLP) for Lifetime Well LLC. Jeffrey J. Goldin (Goldin Law Group, P.C.) for IBSPOT.com Inc.

Companies: Lifetime Well LLC; IBSPOT.com Inc.

News: Trademark Copyright AINews