The Enterprise AI Failure Casebook

The FTC alleged DoNotPay never tested its 'robot lawyer'

DoNotPay sold its chatbot as the world's first robot lawyer, and the FTC alleged the company never tested whether it worked like one.

DoNotPay · January 14, 2025 · Updated October 31, 2026

A subscriber who had been assaulted could open DoNotPay's "Sue Now" feature and talk to its chatbot. According to the Federal Trade Commission's complaint, the chatbot asked for only a "short phrase" describing the incident. Whatever else the subscriber typed at the end got the same reply, a note about updating personal details in the settings menu. The service then produced a half-page demand letter.

DoNotPay sold that service by subscription to consumers in the United States. At times the complaint covers, a General Membership cost 36 dollars every two months. The company's advertising called the service "the world's first robot lawyer" and an "AI lawyer" that could sue anyone at the press of a button. Its website carried a quote attributed to the Los Angeles Times saying the robot lawyer could do what human lawyers do. The complaint says the quote came from a high-school student's opinion piece on the paper's High School Insider site.

The complaint alleges that DoNotPay did not test whether its law-related features operated like a human lawyer. The service was built on a natural language processing model, chatbot software and an API connection to OpenAI's ChatGPT. None of those technologies had been trained on a comprehensive and current body of federal and state law. DoNotPay employees had not tested the quality and accuracy of the documents and advice from most of the law-related features. The company had not employed or retained attorneys to test them. Subscribers complained that the documents it generated were not fit for use.

The State Bar of California had opened an investigation into the service in November 2021 over allegations of the unauthorized practice of law. The complaint says DoNotPay's chief executive promised the bar in January 2022 that the company would stop calling the service the world's first robot lawyer. On June 15, 2023, after a cease-and-desist notice from the bar, DoNotPay said it had removed the phrase. The complaint says the website and social media kept using it.

In September 2024 the FTC accepted a consent agreement for public comment. On January 14, 2025, the Commission issued its complaint and a final order. DoNotPay neither admitted nor denied the allegations. The order requires it to pay 193,000 dollars and to notify customers who subscribed between January 1, 2021 and December 31, 2023 of the settlement. It bars DoNotPay from claiming that the service, or any other online product it offers that purports to provide professional services, performs like a lawyer or another professional unless it holds competent and reliable evidence. The order defines that evidence as tests, analyses, research, studies or other evidence based on the expertise of professionals in the field, conducted and evaluated objectively by qualified people. It ends 20 years after issuance, or later if the government files a federal complaint alleging a violation.

One public comment asked the Commission to require pre-deployment and lifecycle audits of DoNotPay's AI. The Commission declined. It wrote that the substantiation requirement already addresses the company's claims about its AI without specifically mandating testing and auditing.

What failed

DoNotPay did not measure its product against its claim. It said its AI did a lawyer's work, and by the FTC's account it never tested whether the output met that standard, never had a lawyer check it, and kept the claim after promising a regulator it would stop. The record is about advertising, but the gap is one any organization can open internally: a team says an AI tool does a professional's job, the tool goes into use, and no baseline, measure or review by someone qualified in that work was ever set. The FTC's order now makes evidence the condition for the claim. Tests of the kind it names, run before launch, could have shown whether a half-page letter built from one short phrase was fit to send.

Sources

1. FTC, Complaint, In the Matter of DoNotPay, Inc., Docket No. C-4812 (Jan. 14, 2025), Paragraphs 2, 4, 5, 9 to 11, 19 to 21 and 25 to 27
2. FTC, Decision and Order, In the Matter of DoNotPay, Inc., Docket No. C-4812 (issued Jan. 14, 2025), Decision, p. 1; Provision I, pp. 2 to 3; Provision III, p. 3; Provision VI, p. 5; Provision XI, p. 8; issue date, p. 9
3. FTC, Letters to Commenters, In the Matter of DoNotPay, Inc., File No. 232-3042 (Jan. 14, 2025), Letter to the Center for AI and Digital Policy, pp. 3 to 4
4. Federal Register, DoNotPay, Inc.; Analysis of Proposed Consent Order To Aid Public Comment, 89 FR 79594 (Sept. 30, 2024), p. 79594