New York · federal district court · 2025

Flycatcher Corp. Ltd. v. Ozmos Company LLC

District Court, S.D. New York, 26 June 2025 to 18 July 2025. What the court wrote about citations that did not exist, in its own words, from 3 documents on file.

Case record · S.D.N.Y.

  1. Court. District Court, S.D. New YorkCOURT
  2. Level. federal district courtLEVEL
  3. Dates. 26 June 2025 to 18 July 2025DATED
  4. Docket. No. 1:24-cv-09429DOCKET
  5. Judge. Katherine Polk FaillaJUDGE
  6. Documents. 3 documents, 7 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 169, 18 July 2025 · source · PDF · 6 pages

Docket text. ORDER: Accordingly, the Court denies Mr. Feldman's request to amend his brief regarding arbitration because the Court will not allow Mr. Feldman to benefit from failing to substantially raise the issue in the first place. For now, the Court reserves decision on whether to impose sanctions on Mr. Feldman (including the form of such sanctions), and whether to strike the June 20, 2025 brief from the docket and allow him to file an amended brief regarding his non-arbitration arguments. In the meantime, Defendant Top Experience Company LLC's motion to dismiss is pending. (Dkt. #150-152). The Court wants to hear directly from Mr. Feldman, so that it can give him the opportunity to - as he puts it - "prove [himself] worthy to carry the stylus once more in service of justice and truth." (Response 8). Accordingly, Mr. Feldman, and all parties who have appeared in this action, are hereby ordered to appear at a conference on August 14, 2025, at 2:00 p.m., in Courtroom 618 of the Thurgood Marshall United States Courthouse, New York, New York 10007. (Status Conference set for 8/14/2025 at 02:00 PM in Courtroom 618, 40 Centre Street, New York, NY 10007 before Judge Katherine Polk Failla.) (Signed by Judge Katherine Polk Failla on 7/18/2025) (rro) (Entered: 07/21/2025)

On page four of the Response, Mr. Feldman appears to quote from Mata (without providing a pin cite), as follows: Critically, unlike the pattern of deception identified in Mata, where sanctions were imposed not merely for citing fictitious cases but for the attorneys’ “failure to be forthcoming, withdraw the prior submissions, and continue to give legitimacy to fake cases in the subsequent submissions despite having multiple reasons to believe that the cases lacked authenticity,” I immediately acknowledged the errors upon notification and undertook comprehensive corrective action within twenty-four hours. (Response 4 (emphasis added)).

Docket entry 164, 11 July 2025 · source · PDF · 8 pages

Docket text. RESPONSE TO ORDER TO SHOW CAUSE re: 159 Order to Show Cause,. Document filed by Affable Avenue LLC..(Feldman, Steven) (Entered: 07/11/2025)

However, I respectfully submit that these errors do not warrant striking the brief or imposing sanctions because: (1) the errors were inadvertent and resulted from sophisticated AI hallucination mechanisms rather than intentional misconduct; (2) immediat e corrective action was undertaken upon discovery, with a substantially corrected draft prepared within twenty -four hours; (3) no prejudice has resulted to any party; (4) the legal arguments remain substantively sound and supported by legitimate authority; and (5) comprehensive verification protocols have been implemented to prevent recurrence.

2024), and more closely align with circumstances where courts have demonstrated measured approaches to citation inaccuracies. Unlike cases involving wholesale fabrication of authorities or blind reliance on AI-generated content foll owed by deliberate concealment, the errors here arose from a confluence of technical and procedural factors that, while reflecting inadequate verification protocols, fundamentally lack the subjective bad faith that typically triggers severe sanctions. Courts recognize that there is an important difference between unintentional citation mistakes and deliberate attempts to mislead.

Additionally, several errors involved cross-platform citation discrepancies, including parallel citations, unpublished opinions, and formatting inconsistencies between legal databases—technical issues that are distinct from deliberate fabrication of legal principles and reflect the type of inadvertent error that courts have treated with proportional rather than punitive responses.

However, the substantive legal arguments advanced in the memorandum remain grounded in established doctrine and supported by legitimate authority, and the errors did not result in fabrication of legal principles, intentional misrepresentation of law, or material impact on the Court's consideration of the underlying legal issues— factors that courts, including this Court, have recognized as relevant to proportional sanctions analysis.

Moreover, no prejudice has resulted to any party, no judicial resources have been expended on consideration of fictitious authorities, and comprehensive corrective action has been undertaken with systematic procedural safeguards implemented to prevent recu rrence.

Docket entry 159, 26 June 2025 · source · PDF · 2 pages

Docket text. ORDER TO SHOW CAUSE: Accordingly, Mr. Feldman is hereby ORDERED to show cause in writing on or before July 10, 2025, why the brief in support of Affable's motion to dismiss should not be stricken from the docket and sanctions imposed against him pursuant to Federal Rule of Civil Procedure 11. (Signed by Judge Katherine Polk Failla on 6/26/2025) (rro) (Entered: 06/26/2025)

The Court is dismayed to learn that Mr. Feldman might have used a large language model to generate a brief that contains citations to cases that do not exist and citations that are plainly incorrect. The Court is further dismayed to learn that Mr.

What the text mentions

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Where this fits

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More from District Court, S.D. New York, from New York, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

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