Battle v. Microsoft
Battle v. Microsoft — AI Hallucination Defamation Suit Dismissed (D. Md.)
D. Md. · Battle v. Microsoft Corp., No. 1:23-cv-01822 (D. Md.)
- Status
- Repealed / replaced
- Took effect
- August 22, 2024
- Applies to
- Microsoft Corp.
Aerospace consultant Jeffery Battle sued Microsoft alleging Bing/Copilot conflated him with a convicted terrorist of the same name. The case was dismissed in 2024 — among the early dismissals signaling that AI hallucination defamation suits face uphill battles on actual malice and statement-of-fact grounds.
Who is protected: (N/A — dismissed; defamation by AI claims face significant pleading hurdles)
Legal detail
Battle v. Microsoft Corp., No. 1:23-cv-01822 (D. Md., dismissed Aug. 22, 2024; Judge Adam B. Abelson). Court dismissed defamation, false light, and Lanham Act claims; plaintiff failed to plausibly allege Microsoft had actual knowledge of falsity and to plead Bing's outputs as actionable statements of fact.
Key facts
| Jurisdiction | D. Md. |
|---|---|
| Level | Federal |
| Citation | Battle v. Microsoft Corp., No. 1:23-cv-01822 (D. Md.) |
| Topics | consumer protection · AI disclosure and transparency |
| Court record | Battle v. Microsoft — CourtListener 1:23-cv-01822 |
Related consumer protection rules elsewhere
- Missouri AI Therapy Chatbot Ban (SB 1019) · In effect
- Vermont Data Broker Law (H.211) · Enacted (not yet in effect)
- Arkansas Frank Broyles Act AI amendment — voice and likeness protection (2025) · In effect
- PA v. Character.AI (Fake Psychiatrist Chatbot) · Blocked / in litigation
- NAACP v. xAI (Colossus 2 Air Pollution) · Blocked / in litigation
- RI Therapy Chatbot Ban (2026) · In effect
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