From the Louisiana Attorney General's memorandum in a motion to exclude an expert report, filed Friday in Netchoice v. Murrill (links added) (and see also the declaration from the AG's expert analyzing the report, as well as the coverage from Friday on Bloomberg [Jacqueline Thomsen]):
NetChoice submitted Dr. Bean's expert report to Defendants, along with the original sources on which he allegedly relied. While the original sources NetChoice produced exist, the substance of Dr. Bean's report is fake. None of the 17 articles in Dr. Bean's reference list exists, and his report never cites the actual sources NetChoice provided to Defendants. More, none of the 12 quotations that Dr. Bean's report attributes to various authors and articles exists (even in the original sources provided to Defendants).
A cursory comparison between Dr. Bean's report and the disclosed original sources would have alerted NetChoice that something is amiss. In fact, just reading Dr. Bean's report would have done so. His reference list makes no sense, (a) citing website links that are dead or lead to entirely unrelated sources and (b) citing volume and page numbers in publications that are easily confirmed to be wrong. And his report itself is strangely formatted, not least because, well, it looks and reads like a print-out from artificial intelligence (AI).
Dr. Bean's report bears all the telltale signs of AI hallucinations: completely fabricated sources and quotations that appear to be based on a survey of real authors and real sources. See, e.g., Brandon Fierro, Short circuit court: AI hallucinations in legal filings and how to avoid making headlines, Reuters (Aug. 4, 2025 8:27 AM), t.ly/inw31. It is difficult to escape the irony of a NetChoice expert submitting an expert report based on non-existent authorities and quotations. Yet here lies NetChoice—a loud proponent of "free expression" and "AI's Transformative Power"—attempting to rely on such a report and such an expert in this litigation.
