Battle v. Microsoft — AI Hallucination Defamation Suit Dismissed (D. Md.)
D. Md. · Battle v. Microsoft Corp., No. 1:23-cv-01822 (D. Md.)
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.
Technical 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.
Who is protected: (N/A — dismissed; defamation by AI claims face significant pleading hurdles)
Who must comply: Microsoft Corp.
Key facts
| Jurisdiction | D. Md. |
|---|---|
| Level | Federal |
| Status | Repealed / replaced |
| Protection strength | Limited protection |
| Effective date | 2024-08-22 |
| Citation | Battle v. Microsoft Corp., No. 1:23-cv-01822 (D. Md.) |
| Topics | consumer protection · AI disclosure and transparency |
| Last verified | 2026-06-17 |
| Official source | Battle v. Microsoft — CourtListener 1:23-cv-01822 ↗ |
Related consumer protection rules elsewhere
- FTC Act Section 5 (unfair/deceptive AI) · In effect
- TAKE IT DOWN Act · In effect
- FCRA (AI in credit & background checks) · In effect
- ECOA / Regulation B (AI credit discrimination) · In effect
- COPPA + 2025 Rule (childrens data) · In effect
- TCPA (AI voice calls) · In effect
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