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SDNY Rules Public GenAI Exchanges Aren’t Protected by Privilege or Work Product

The ruling spotlights confidentiality plus counsel direction as the decisive factors.

Overview

  • U.S. District Judge Jed S. Rakoff held that a defendant’s exchanges with Anthropic’s public Claude platform are not covered by attorney-client privilege or the work-product doctrine.
  • The court cited the platform’s privacy policy allowing data retention and disclosure and emphasized that the AI use was initiated by the client, not at counsel’s direction.
  • Agents had seized roughly 31 AI-related memoranda from Bradley Heppner’s devices, and the court found that sharing those materials with lawyers after the fact did not create protection.
  • The decision framed work product as protecting attorneys’ mental impressions, rejected client-initiated AI materials as qualifying, and disagreed with more expansive readings in earlier SDNY rulings.
  • Other courts have reached different results in fact-specific settings, including a Michigan decision treating GenAI as a tool and denying discovery of AI-use materials, and a prior case protecting counsel-directed prompts as opinion work product.