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| # United States Department of Justice | |
| ## Civil Division — Internal Memorandum | |
| --- | |
| ## Subject | |
| Assessment of AI-Assisted FOIA Research Tool | |
| **Federal FOIA Intelligence Search** | |
| --- | |
| ## Purpose | |
| This memorandum evaluates the legal, evidentiary, and litigation-risk | |
| implications of references to the above-described tool in civil filings, | |
| FOIA litigation, or administrative records. | |
| --- | |
| ## Tool Description | |
| Federal FOIA Intelligence Search is a **third-party, non-governmental research aid** | |
| that aggregates links to agency FOIA electronic reading rooms and generates | |
| citations, appendices, and optional AI summaries. | |
| The system: | |
| - Does not host or alter government records | |
| - Does not interface with agency systems | |
| - Does not generate factual determinations | |
| --- | |
| ## Litigation Risk Analysis | |
| ### Evidentiary Risk | |
| Minimal. All primary evidence remains agency-authored and publicly hosted. | |
| ### Discovery Risk | |
| Low. No user data retention; no document caching; no training on user input. | |
| ### Attribution Risk | |
| Mitigated by: | |
| - Mandatory disclosure blocks | |
| - Citation hashes | |
| - Clear AI labeling | |
| --- | |
| ## FOIA Litigation Context | |
| Use of the tool: | |
| - Does not constitute agency action | |
| - Does not alter the administrative record | |
| - Does not substitute for Vaughn indices or sworn declarations | |
| --- | |
| ## DOJ Guidance | |
| Attorneys encountering this tool in filings should: | |
| 1. Focus review on underlying FOIA documents | |
| 2. Treat AI summaries as non-evidentiary | |
| 3. Confirm citations independently where material | |
| 4. Raise objections only if AI output is misrepresented as fact | |
| --- | |
| ## Conclusion | |
| > Federal FOIA Intelligence Search presents **no novel legal risk** beyond ordinary | |
| citation tools when properly disclosed. | |
| Its architecture aligns with DOJ principles of transparency, restraint, | |
| and evidentiary integrity. |