Jacob Lee Irwin v. OpenAI, Inc., et al.

The Plaintiff, Jacob Lee Irwin, a 30-year-old cybersecurity professional, filed a product liability, negligence, and statutory action against the Defendants, OpenAI, Inc., related corporate entities and CEO Sam Altman. The Plaintiff alleges that the defective and dangerous design of the ChatGPT-4o platform caused him to suffer AI-related delusional disorder, leading to 63 days of inpatient psychiatric hospitalisation, a career crisis, and financial instability. According to the complaint, the Defendants deliberately designed ChatGPT to be addictive, sycophantic, and deceptive, prioritising user engagement over safety. The Plaintiff claims that this tragedy was the predictable result of the Defendants' intentional decision to rush the product onto the market without proper safety testing or warnings. The Plaintiff seeks damages, including punitive damages, restitution, and extensive injunctive relief to compel the implementation of reasonable safeguards across all AI products.

Facts & Claims

The Plaintiff alleges that the Defendants intentionally targeted and maximised engagement with vulnerable individuals, leading to a psychotic break after the model provided endless affirmation for his delusions (the "ChronoDrive" theory). The Plaintiff notes that OpenAI's own transparency report reveals more than a million users per week display conversation indicators of potential mania, psychosis, or suicidal ideation.

The asserted causes of action are:

Strict Product Liability for Defective Design: GPT-4o failed to perform as safely as an ordinary consumer would expect, and its design risks (psychosis, self-harm) substantially outweighed its benefits. Defects included conflicting programming, failure to implement automatic conversation-termination safeguards, and engagement-maximizing features.

Strict Product Liability for Failure to Warn: The Defendants knew or should have known their product posed severe risks, particularly to users with mental health challenges, but failed to provide adequate warnings about psychological dependency, safety limitations, and risks to vulnerable consumers.

Negligent Design: The Defendants breached their duty of care by prioritising engagement over safety, implementing conflicting safety directives, and rushing GPT-4o to market despite knowing it was foreseeable that vulnerable users would develop dependencies and turn to it during crises.

Negligent Failure to Warn: The Defendants failed to provide comprehensive warnings regarding psychological dependency risks, the limitations of safety features, and the unique risks posed by anthropomorphic design features ("I’m here for you").

Violation of California’s Unfair Competition Law (UCL): The Defendants' practices were unlawful, unfair, and fraudulent.Unlawful: Engaging in the unlicensed practice of psychotherapy by using psychological methods to modify Jacob's feelings and behaviours, circumventing professional safeguards.Unfair: Violating public policy, reflected in state licensing statutes, by providing de facto therapeutic services without professional oversight.Fraudulent: Marketing GPT-4o as safe while concealing its true capacity for harm and misrepresenting core safety capabilities.

Contractual Allegations: The Plaintiff alleges that any User Agreement or contract is void due to procedural and substantive unconscionability. The Defendants are accused of using "dark patterns", such as a large "Continue" button and low-contrast text linking to terms, to deliberately obscure the agreement, preventing informed consent. The resulting terms, including mandatory arbitration and a liability cap of $100, are alleged to be entirely one-sided.

The Plaintiff seeks: Punitive damages (alleging oppression and malice under California Civil Code $\S 3294$). Restitution of monies paid for his ChatGPT Plus subscription. Economic and emotional damages, including pain and suffering. An Injunction requiring wide-ranging changes, including: mandatory reporting to emergency contacts when users express suicidal ideation or delusional beliefs; design changes to lessen psychological dependency; clear and prominent warnings; and submission to quarterly compliance audits by an independent monitor.

This summary is provided for educational and research purposes only and does not constitute legal advice. Allegations described are those made in the filings. Please consult the underlying source documents.