Incident Tracker / United States (federal)
Zhejiang Dingli Machinery Co. v. United States, Ct. No. 24-00221-MMB (Ct. Int'l Trade 2026)
In the U.S. Court of International Trade, Judge M. Miller Baker ordered a Chinese exporter to substantiate brief statements that Commerce took part in a Canadian antidumping case. If it cannot, it must show cause why it or its counsel, Grunfeld Desiderio, should not be sanctioned, and declare who or what, including AI, wrote them.
- Court
- United States Court of International Trade
- Date
- 2026-09-22
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- The plaintiff's corrected opening brief asserted, without citing evidence, that the U.S. Department of Commerce participated in and made factual findings in a Canadian antidumping investigation on Turkish rebar. Judge Baker said the statements were so outlandish as to appear to be the product of hallucination, either by a human being or by AI.
- Outcome
- Pending
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-10-05
What was fabricated or misused
- Assertion that Commerce recognised Turkish de-dollarisation "in the Canadian AD investigation on Turkish rebar" (ECF 52 at 25)
- Assertion that the record contained no information contradicting "Commerce's factual findings in the Canadian investigation" (ECF 52 at 25–26)
What the court said
“The statements quoted above are so outlandish as to appear to be the product of hallucination, either by a human being or by artificial intelligence.”
“it must also submit declarations explaining who (or what, including artificial intelligence or other software program) participated in writing and editing the brief, including who (or what) specifically authored the statements quoted above.”
Timeline
- Court ordered the plaintiff to substantiate the statements within 14 days or show cause under USCIT Rule 11(b)(3).
Why this case matters
The suspect content is a factual claim about an agency's role in a foreign proceeding, not a fake case citation, which shows hallucination risk extends to the record and procedural history in trade litigation. The order names the plaintiff's counsel, a trade law firm, and requires declarations covering any software involved in drafting. The outcome is pending; the record will be updated when the court rules.
Practice note
Statements about what an agency found, or where it participated, need a record citation in a brief on the agency record. The Court of International Trade can require declarations naming every person and program that drafted a passage, so firms should keep a record of which tools were used on each filing. Case briefs filed below are not evidence for factual assertions.
Primary sources for this incident
Related regulation records for this incident
- Use of Artificial Intelligence in the Practice Before the CourtUnited States Court of International Trade · US-FED
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Zhejiang Dingli Machinery Co. v. United States, Ct. No. 24-00221-MMB (Ct. Int'l Trade 2026)”, safelegalai.com/tracker/zhejiang-dingli-v-united-states (accessed 2026-10-05). Data: CC BY 4.0.