AI use undisclosed (Lexis+AI per the case record). The court issued an order to show cause.
Flowz Digital LLC sued Caroline Dalal and others. After Flowz filed its opposition to the defendants' motion to dismiss, the court spotted potential errors and ordered Flowz to disclose whether it used generative AI. Counsel Omid Khalifeh filed a declaration admitting an AI tool was used in early drafting to help identify legal authorities and organize arguments. The court's standing order required a separate declaration disclosing AI use and certifying the content had been verified, and counsel gave no reason for skipping it.
The court then questioned the cited authorities. Flowz cited In re Daou Systems, Inc., 411 F.3d 1006 (9th Cir. 2005) for a direct-versus-derivative claims principle, but the court noted that case never addressed that distinction. Flowz also cited S.E.C. v. Cross Financial Services for a pleading-stage proposition about corporate control, but the court found that case dealt with subject-matter jurisdiction over a nominal defendant in a securities case.
The court added that after multiple search attempts it could not locate Shell Petroleum N.V. v. Republic of Costa Rica, 608 F. Supp. 2d 269 (S.D.N.Y. 2009), and ordered Flowz to attach that case to its response.
Offered for: a direct-versus-derivative distinction
The court issued an order to show cause, in writing, by May 12, 2025, why Flowz and its counsel should not be sanctioned under Rule 16(f) for violating the court's AI standing order and under Rule 11 for filing an opposition without a reasonable inquiry into whether its legal contentions were supported. It noted that although the case had been stayed and administratively closed, it retained jurisdiction to impose sanctions.
Kingsfield returned REJECT. The court could not locate this case after several searches. The brief also cited a real case for a distinction it never drew, and did not disclose AI use as the court's standing order required.
This matter is among the US case-law cases we ran Kingsfield against in the Charlotin benchmark. Kingsfield's existence check confirms every citation against the case-law corpus and an independent source (CourtListener) before any claim resting on it can stand. Across the run Kingsfield ruled 696 of 700 testable claims correctly, including every one of the 504 fabricated citations and 92 fabricated quotes.
Honest scope. This measures Kingsfield's ruling layer given an extracted citation, not an end-to-end run over a full brief. The case record and the AI-tool attribution come from Damien Charlotin's public database and the court order; the verdict is Kingsfield's. See the full 700-claim benchmark.