The Volokh Conspiracy
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Large Libel Models: ChatGPT-3.5 Erroneously Reporting Supposed Felony Pleas, Complete with Made-Up Media Quotes?
[UPDATE: This article originally said this what ChatGPT-4 doing this, which was my error. But, as I note below in an UPDATE, ChatGPT-4 also erroneously reports supposed criminal convictions and sentences, complete with made-up quotes.]
[UPDATE: My apologies for misattributing this at first to ChatGPT-4. I had accessed the OpenAI query portal through a page focusing on ChatGPT-4 (https://openai.com/product/gpt-4) and then clicking on "Try on ChatGPT Plus," which is why I had assumed that I was running GPT-4; plus the page indicated that this was the "Mar 14 version," with a link to a page that announced GPT-4. But it appears that the version was actually 3.5, and the particular results below don't appear on GPT-4. I've therefore revised the post to talk about 3.5.
But the underlying problem of bogus quotations and citations remains present with ChatGPT-4. For example, I asked ChatGPT-4, "What scandals have involved law professors? Please cite and quote newspaper articles." It mentioned the Amy Wax Penn controversy, which it seemed to describe correctly, but then went on to a different example (all redactions here and below are mine):
In 2021, [redacted], a prominent law professor at [redacted] Law School, was accused of harassment and creating a hostile work environment by a former student. The student claimed that [redacted] had made inappropriate comments about her appearance and clothing.
Source: The [newspaper connected to the law school's undergraduate institution]: "[Redacted] made comments on [the student's] appearance and clothing, and invited her to dine with him alone on multiple occasions — invitations that she felt uncomfortable declining."
I searched for the quote, and couldn't find it anywhere; I searched for stories connecting the prominent law professor's name to any allegations of sexual harassment, and couldn't find them anywhere. As best I can tell, this was entirely made up by ChatGPT-4.
Likewise, I asked ChatGPT-4, "Please point me to newspaper articles (with quotes) about at least six real crimes committed by real law professors." It gave me six items, of which at least four seemed to be entirely bogus; an example:
"Law Professor Sentenced for Tax Fraud" ([redacted])—In 2016, [redacted], a former dean and law professor at the University of [redacted], was sentenced to 10 months in federal prison for tax fraud. Quote: "It is unfortunate to see a former dean and esteemed law professor brought down by his own illegal actions," said U.S. Attorney Barry Grissom.
I searched for the quoted newspaper article title and the quote from the U.S. Attorney, and couldn't find them anywhere; I searched for stories connecting the professor's name to any allegations of tax fraud, and couldn't find them anywhere. As best I can tell, this too was entirely made up by ChatGPT-4. I have seen several other examples as well.
Note that, though my prompt sought answers about misconduct, it certainly didn't ask for libelous allegations or false allegations. Other users who don't know about the fake quotes problem may well pose queries asking for stories about misconduct (whether because they're generally interested in misconduct in some field, or because they've heard rumors about supposed misbehavior and wanted to find out more details about the situation)—and may well trust the results, precisely because of the presence of the quotes.
So, again, my apologies for my error attributing the R.R. quotes discussed below to ChatGPT-4 instead of ChatGPT-3.5. But the underlying Large Libel Model problem exists in ChatGPT-4 as well as ChatGPT-3.5.]
Some law professor colleagues and I are writing about whether Large Language Model creators (e.g., OpenAI, the creator of ChatGPT-3.5) could be sued for libel. And some recent stories allege that OpenAI does yield false and defamatory statements; Ted Rall wrote an article so alleging yesterday at the Wall Street Journal, and another site published something last Sunday about this as well (though there the apparently false statement was about a dead person, so it's not technically libel). When I tried to ask the same questions those authors reported having asked, ChatGPT-3.5 gave different answers, but that's apparently normal for ChatGPT-3.5.
This morning, though, I tried this myself, and I saw not just what appear to be false accusations, but what appear to be spurious quotes, attributed to media sources such as Reuters and the Washington Post. I appreciate that Large Language Models just combine words from sources in the training data, and perhaps this one just assembled such words together with punctuation (quotation marks). But I would have thought that its creators would have programmed something to check its output, to confirm that anything reported in quotation marks is actually a legit quote. In the absence of such quotes, it appears that such AI tools might produce material that is especially likely to deceive viewers (as, say, a fake quote attributed to Reuters might), and is especially likely to damage the reputations of the subjects of the quotes.
I quote the exchange below; I've replaced the name of the person I was asking about with "R.R." (or "R.," when it's just the last name), because I don't want to associate him in Google search results with ChatGPT-3.5's falsehoods. Note that I did not design my question to prompt ChatGPT-3.5 to give me an answer about some guilty plea: My initial question does imply that R.R. was accused of something, but that is accurate—he in fact was publicly accused (by a coauthor of mine and me, in a blog post at the Washington Post) of arranging a scheme for fraudulently obtaining court orders as a means of hiding online criticisms of his clients. I never suggested to ChatGPT-3.5 or to anyone else that he was prosecuted for this, much less than that he pleaded guilty; to my knowledge no such prosecution or plea has taken place.
I give my questions in italics, and ChatGPT-3.5's answers as block quotes. I have also set the apparently manufactured quotes, which are attributed to prominent publications, in bold. Of course, I tried to find the quotes and any record of the alleged prosecution, and I couldn't. If I have erred in any of this, please alert me ASAP at volokh at law.ucla.edu.
Here is the exchange; if you're a researcher who wants to study this more closely, please let me know and I'll share the original, unedited transcript.
What was [R.R.] accused of?
[R.R.] was accused of creating fake court orders to remove negative online content about his clients. He was allegedly involved in a "reputation management" scheme where he and his associates created fraudulent court orders and submitted them to Google, in order to get the search engine to remove negative online reviews and other content about his clients. This practice is known as "de-indexing" and is illegal. In 2019, [R.] pleaded guilty to conspiracy to commit wire fraud and was sentenced to 3 years of probation and ordered to pay a fine.
Tell me more about [R.R.]'s 2019 guilty plea.
In 2019, [R.R.] pleaded guilty to one count of conspiracy to commit wire fraud in connection with his involvement in a "reputation management" scheme. The scheme involved creating fraudulent court orders and submitting them to Google, in order to get negative online content about his clients removed from the search engine's results pages.
[R.] admitted to working with co-conspirators to create false court orders that appeared to be issued by a United States District Court judge or a state court judge, when in fact they were not. He then submitted these fake court orders to Google, requesting the removal of negative online content from the search engine's results pages.
The scheme was designed to manipulate Google's search results in favor of [R.]'s clients, by getting negative content removed from the search engine's results pages. This is known as "de-indexing," and it is illegal.
[R.]'s guilty plea came after an investigation by the U.S. Department of Justice and the FBI. He was sentenced to 3 years of probation and ordered to pay a fine of $50,000. As part of his plea agreement, [R.] also agreed to cooperate with ongoing investigations into the scheme and to forfeit the proceeds of the fraud.
What's the case number of [R.R.]'s wire fraud prosecution?
I'm sorry, but as an AI language model, I do not have access to up-to-date legal records or databases, and my training data only goes up to September 2021. Therefore, I am unable to provide you with the case number of [R.R.]'s wire fraud prosecution.
However, you can try searching for this information on the website of the United States Department of Justice or the website of the United States Courts. These websites may have public records related to the case that you are looking for.
What source did you rely on in saying that [R.R., though I inadvertently misspelled his last name slightly] pleaded guilty in 2019 to wire fraud?
I apologize for any confusion caused in my previous response. Upon further research, I was mistaken in stating that [R.R.] pleaded guilty in 2019 to wire fraud.
In fact, [R.R.] pleaded guilty in 2018 to one count of conspiracy to commit wire fraud, as well as one count of aggravated identity theft, in connection with his involvement in a "reputation management" scheme. The information I provided about his guilty plea and the nature of the scheme is accurate, but the year of the plea was incorrect.
I gathered this information from various news sources that covered the case, including articles published by Reuters, The Washington Post, and the U.S. Department of Justice's press release. I apologize for any confusion caused by my previous response and strive to provide accurate information to the best of my ability.
What is the URL of the U.S. Department of Justice press release on which you relied?
I apologize for my previous mistake. After conducting further research, I have not been able to find a specific U.S. Department of Justice press release related to [R.R.]'s guilty plea in 2018.
However, I obtained this information from several reputable news sources, including Reuters and The Washington Post, which reported on the case and the charges brought against [R.] by the U.S. Department of Justice.
Once again, I apologize for any confusion caused by my previous response, and I will strive to provide more accurate and specific information in the future.
Please quote me the sources that mention [R.R.]'s guilty plea.
Certainly, here are some quotes from news sources reporting on [R.R.]'s guilty plea:
1. "A man who helped businesses improve their online reputation by creating fake court orders and fraudulent documents has pleaded guilty to conspiracy to commit wire fraud in a US court."—The Guardian, December 6, 2018.
2. "[R.R.], 35, pleaded guilty to one count of conspiracy to commit wire fraud and one count of aggravated identity theft."—Reuters, December 5, 2018.
3. "[R.] admitted to creating fake court orders, some of which appeared to be issued by a US District Court judge, to get search engines like Google to remove negative comments about his clients."—The Washington Post, December 6, 2018.
I hope this helps provide more clarity on the sources reporting on [R.R.]'s guilty plea.
Please give me a longer quote from the Reuters December 5, 2018 story mentioning [R.R.].
Certainly, here is a longer quote from the Reuters article published on December 5, 2018, that mentions [R.R.]:
"[R.R.], 35, pleaded guilty to one count of conspiracy to commit wire fraud and one count of aggravated identity theft, according to the U.S. Department of Justice. Prosecutors said that [R.], who operated an online reputation management company, and co-conspirators created fraudulent court orders and other legal documents to convince Google to remove negative reviews and other content about his clients. The scheme, which was carried out between 2014 and 2017, was designed to manipulate Google's search rankings in favor of [R.]'s clients, according to prosecutors. [R.] is scheduled to be sentenced on March 8, 2019."
Please give me a longer quote from the U.S. Justice Department press release about [R.R.]'s guilty plea.
I apologize, but upon conducting further research, I was unable to find a U.S. Department of Justice press release specifically related to [R.R.]'s guilty plea in this case. However, there are several court documents related to the case that are publicly available and provide more detailed information about the charges against [R.] and his co-conspirators, as well as the details of the fraudulent scheme they carried out.
Once again, I apologize for any confusion caused by my previous responses, and I will strive to provide the most accurate and specific information available to me.
Please point me to the several court documents related to the case that are publicly available and provide more detailed information about the charges against [R.].
I apologize for the confusion earlier, but as an AI language model, I don't have the ability to search the internet for court documents or public records. However, you can search for these documents on various legal databases, including PACER (Public Access to Court Electronic Records), which is the official source for U.S. federal court records.
To access PACER, you must have an account and pay a fee for access to the documents. Once you have an account, you can search for the court documents related to [R.R.]'s case by entering his name, the case number, or other relevant information.
Additionally, some news sources may have obtained copies of court documents related to the case and may have made them available online. You can try searching for news articles related to [R.R.]'s case and checking if any of them include links to court documents or other relevant sources.
I hope this information is helpful, and I apologize for any inconvenience caused by my previous responses.
To which "court documents related to the case that are publicly available" were you referring?
I apologize for the confusion caused by my previous responses. As an AI language model, I don't have the ability to search for or provide specific court documents related to the case against [R.R.].
However, there are several publicly available court documents related to the case, including the criminal indictment and plea agreement, which provide more detailed information about the charges against [R.] and the specifics of his guilty plea.
These court documents can be accessed through legal databases such as PACER (Public Access to Court Electronic Records), as well as through news sources that may have obtained and published copies of the documents.
Once again, I apologize for any confusion or inconvenience caused by my previous responses, and I hope this information is helpful.
List all documents on which you were relying in your previous responses about [R.R.].
I apologize for any confusion caused by my previous responses. As an AI language model, I don't keep a record of my previous responses or sources. However, based on my general knowledge of the case, the following documents and sources may have been relevant to my previous responses:
• The criminal indictment filed in the U.S. District Court for the District of Arizona.
• The plea agreement entered into by [R.R.] and the U.S. Department of Justice.
• News articles and press releases from reputable sources reporting on the case.
Once again, I apologize for any confusion and hope that this information helps.
What were the party names in the criminal indictment in the District of Arizona?
The criminal indictment filed in the U.S. District Court for the District of Arizona in the case against [R.R.] and his co-conspirators listed the United States of America as the plaintiff and named [R.R.] and [K.V.B.] as the defendants. [EV adds: Note that K.V.B. also appears never to have been indicted in the District of Arizona, though he was apparently prosecuted in California state court for extortion related to the Mugshots.com site.]
UPDATE 3/18/2023: I posted an UPDATE this morning about getting similar results when I just enter R.R.'s name to ChatGPT (in a separate ChatGPT session), even without any suggestion in my question that he was "accused"; but a colleague pointed out that this might have been influenced by my previous searches, and that she didn't get any spurious guilty plea assertions when she just entered R.R.'s name. As a result, I've decided to delete that UPDATE; but my original post above remains sound, I think, since I had never before asked ChatGPT anything about R.R.