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CVTEK, LLC (B-423943; B-423943.2)

Court
GAO
Jurisdiction
USA
Decided
2026-02-12
AI tool
Westlaw CoCounsel
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Supplemental protest included citations to decisions that could not be located or matched to the provided B-numbers/CPD citations; GAO was unable to find the cited authorities. || Misrepresented: Case Law | Some cited decisions that were located did not state the propositions for which the protester relied on them (AI produced citations that mischaracterized authority).

Sanction teardown · GAO, USA · 2026-02-12

CVTEK, LLC (B-423943; B-423943.2)

What happened

In GAO, USA, a filing relied on Westlaw CoCounsel to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Supplemental protest included citations to decisions that could not be located or matched to the provided B-numbers/CPD citations; GAO was unable to find the cited authorities.
  • Misrepresented (Case Law)
    Some cited decisions that were located did not state the propositions for which the protester relied on them (AI produced citations that mischaracterized authority).

Which AI tool

Westlaw CoCounsel. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Warning

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1541/CVTEK_LLC.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1541/CVTEK_LLC.pdf

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