In Tremblay v. OpenAI, Inc., California District Judge Araceli Martinez-Olguin granted plaintiff’s motion for relief in a prompts and outputs production order, finding that the order to produce all prompts and outputs for Plaintiffs’ testing of ChatGPT was a “misapplication of law” because “the ChatGPT prompts were queries crafted by counsel and contain counsel’s mental impressions and opinions about how to interrogate ChatGPT”.

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