Courts on AI / Discovery and AI-assisted review
Morgan v. V2X, Inc.
U.S. District Court for the District of Colorado · Federal district courts · CO · · No. 1:25-cv-01991-SKC-MDB · order
On 2026-03-30, the District of Colorado amends a protective order in an employment case involving a pro se plaintiff’s AI use. The court protects party work product, requires disclosure of the AI platform used with confidential information, and bars uploads to tools lacking contractual safeguards.
- Disposition
- The court granted in part and denied in part the motion to amend the protective order and required disclosure of the AI platform used with confidential information.
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
Here, like in Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026), Plaintiff can assert work product protections in connection with his AI use. It is true that AI systems like ChatGPT, Claude, Gemini, and others widely available to the public, collect user data for training and other purposes. But in this Court’s estimation, that does not eliminate all expectations of privacy or automatically waive protections. ... If Plaintiff already submitted Confidential Information to some AI system—and it appears he has—Defendant is entitled to know which system. ... No party or authorized recipient may input, upload, or submit CONFIDENTIAL Information into any modern artificial intelligence platform, including any generative, analytical, or large language model-based tool (“AI”), unless the AI provider is contractually prohibited from: (1) storing or using inputs to train or improve its model; and (2) disclosing inputs to any third party except where such disclosure is essential to facilitating delivery of the service.
Authorities cited in the passage: Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026) · United States v. Heppner, 2026 WL 436479 (S.D.N.Y. Feb. 17, 2026) · Fed. R. Civ. P. 26(b)(3)
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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