Thank You – Citation Re AI Protective Orders

A Request to Serve a Categorical Privilege Log for 8,000 Documents Was Denied
September 14, 2026

Thank you to Cimplify for citing one of my blogs on protective orders.   Stepping Up to the Plate: Protective Orders to Restrict AI Training on Produced Data – Cimplifi

Cimplify discussed a number of cases and wrote:

As noted by Michael Berman in his blog for his site E-Discovery LLC, “Protective orders addressing the use of A.I. to review materials produced to an opponent in discovery are becoming routine.”

Cimplify concludes: “Given the risks associated with public AI platforms, protective orders that limit the ability of opposing parties to upload sensitive and confidential produced documents into a public AI tool are essential today. But the considerations associated with AI are changing rapidly. It’s important to keep that in mind when drafting your own protective order to protect your organization’s sensitive and confidential data.”

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