# 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.