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ARTICLE · 16 JULY 2025

(Pro) Health Issues Lead To Hallucinations...

Lewis Silkin
Lewis Silkin
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Lewis Silkin

Lewis Silkin

Joint managing partners: Jo Farmer, Richard Miskella International offices: Dublin, Hong Kong...

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The case of Pro Health Solutions ltd v ProHealth Inc [2025] 6 WLUK 622 involved an appeal before the Appointed Person (AP) in the Trade Marks Registry, decided on 20 June 2025.

United KingdomIntellectual Property

The case of  Pro Health Solutions ltd v ProHealth Inc [2025] 6 WLUK 622 involved an appeal before the Appointed Person (AP) in the Trade Marks Registry, decided on 20 June 2025. The dispute centred on trade mark registration and invalidation proceedings, with the appellant, a litigant-in-person, challenging decisions that had favoured the respondent, ProHealth Inc. The appeal was ultimately dismissed, but the case is notable for its detailed consideration of the use of generative artificial intelligence (AI) in legal submissions, particularly the citation of fabricated authorities, otherwise known as a hallucination. Hallucinations are one of the limitations of large language models like ChatGPT, where the model occasionally generates outputs that are factually incorrect and do not correspond to information in the training data.

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