From the declaration filed today by the expert witness in Kohls v. Ellison (D. Minn.), a case challenging the Minnesota restriction on AI deepfakes in election campaigns:
[1.] I am writing to acknowledge three citation errors in my expert declaration, which was filed in this case on November 1, 2024 (ECF No. 23). I wrote and reviewed the substance of the declaration, and I stand firmly behind each of the claims made in it, all of which are supported by the most recent scholarly research in the field and reflect my opinion as an expert regarding the impact of AI technology on misinformation and its societal effects. Attached as Exhibit 1 is a redline version of the corrected expert declaration, and attached as Exhibit 2 is a redline version of the corrected list of academic and other references cited in the expert declaration.
[2.] The first citation error appears in paragraph 19 and cites to a nonexistent 2023 article by De keersmaecker & Roets. The correct citation for the proposition is to Hancock & Bailenson (2021), cited in paragraph 17(iv). The second citation error appears in paragraph 21, a citation to a nonexistent 2023 article by Hwang et al., and is identified by the Plaintiffs in their motion to exclude my declaration. The correct citation for that proposition is to Vaccari & Chadwick (2020), which appears in paragraph 20. The third citation error appears in Exhibit C to the declaration (ECF No. 23-1, at 39): the citation to Goldstein et al. lists the first author correctly, but the remaining authors are incorrect. The correct authors are Goldstein, J., Sastry, G., Musser, M., DiResta, R., Gentzel, M., and Sedova, K. I discovered the errors in paragraph 19 and Exhibit C when Plaintiffs brought the error in paragraph 21 to the Court's attention, and I re-reviewed my declaration.
[3.] I apologize to the Court for these three citation errors, and I explain how they came to be below. I did not intend to mislead the Court or counsel. I express my sincere regret for any confusion this may have caused. That said, I stand firmly behind all of the substantive points in the declaration. Both of the correct citations were already cited in the original declaration and should have been included in paragraphs 19 and 21. The substantive points are all supported by the scientific evidence and correcting these errors does not in any way alter my original conclusions.
