Court Denies Motion to Seal AI-Generated Competitive Research Report

Posted: May 22, 2026 / Written by: Samuel L. Butt, Thomas A. Kissane, Ian Weiss, Channing J. Turner / Categories Court Rules/Procedures, Sealing/Confidentiality, Confidentiality

Court Denies Motion to Seal AI-Generated Competitive Research Report

On April 19, 2026, in AlphaSense, LLC v. Richards, Index No. 650202/2026, Justice Andrea Masley granted in part and denied in part plaintiff’s motion to seal two exhibits. Plaintiff sought to seal a report on defendant Daloopa, Inc.’s business performance that had been generated using plaintiff’s artificial-intelligence platform, as well as a “competitive intel” Slack channel post. Plaintiff argued that both documents contained proprietary, confidential, and commercially sensitive information. The Court denied sealing as to the AI-generated report, reasoning that the report concerned defendant Daloopa’s own business rather than plaintiff’s proprietary information; that the report carried a disclaimer acknowledging it was AI-generated, might contain inaccuracies, and instructing users to verify with original sources; and that plaintiff had routinely disseminated similar reports to prospective customers without any confidentiality designation. The Court granted sealing as to the Slack post, which referenced plaintiff’s large language model technology. In denying sealing of the AI-generated report, the Court explained:

Further, the report is AI generated. The bottom of every page consists of a disclaimer: “This Generative Search result is Al-generated and may include inaccuracies. Use discretion and verify with original sources. See additional disclaimers located at the back of this report.” . . . This shows that the report . . . is not an original source and may not be entirely accurate. This undermines plaintiff’s argument for sealing because it supports defendants claim that the original sources were publicly accessible.

The attorneys at Schlam Stone & Dolan LLP have extensive experience handling sealing and confidentiality disputes in complex commercial litigation. Contact the Commercial Division Blog Committee at commercialdivisionblog@schlamstone.com if you or a client have questions concerning such issues.