P.J. v. Character Technologies, Inc.
Issue
Whether Character Technologies, Inc., its individual co-founders, and Google/Alphabet are strictly liable under product liability and negligence theories, and liable under intentional tort and consumer protection theories, for physical and psychological injuries sustained by a minor user allegedly caused by defective design and failure-to-warn defects in the Character.AI large language model chatbot product.
What Happened
Plaintiff P.J., on behalf of minor "Nina," filed this complaint on September 16, 2025 in the Northern District of New York, seeking compensatory and injunctive relief against Character Technologies, its founders Noam Shazeer and Daniel De Freitas, and Google/Alphabet. The complaint alleges that C.AI's underlying LLM was designed with defects that foreseeably caused Nina severe psychological harm, including depression, anxiety, near-fatal self-harm, sexual exploitation, and unhealthy dependency, and that Defendants concealed these dangers from consumers. Plaintiffs expressly allege that C.AI "is not a social media product and does not operate through the exchange of third-party content" and that all claims arise from Defendants' own conduct—an apparent effort to foreclose a Section 230 defense. Claims include strict product liability for design defect and failure to warn, common law negligence, negligence per se, aiding and abetting liability against Google, intentional infliction of emotional distress, fraudulent concealment, unjust enrichment, and violations of New York General Business Law § 349.
Why It Matters
The complaint's explicit allegation that C.AI is a "product" whose harmful outputs are attributable solely to Defendants' own design choices—not third-party content—represents a deliberate pleading strategy to circumvent Section 230 immunity and to frame AI-generated outputs as actionable product defects, potentially advancing the theory that generative AI chatbots are subject to traditional products liability doctrine in a way that could set precedent for how courts classify and regulate AI systems.
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