The meteoric rise of generative artificial intelligence (Gen AI) has exposed a systemic vulnerability in the corporate legal shield. As a "question of first impression," the decision in United States v. Heppner (2026) is the first to explicitly deny privilege to AI-generated documents. Its significance lies in the clear signal that the mere involvement of a client and a legal topic does not invoke the protections of the law.

As discussed in our January 2026 memo, beginning in March 2026, directors and officers of “Foreign Private Issuers” (FPIs) will be required to make public EDGAR filings pursuant to Section 16(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) of Forms 3, 4 and 5.  These forms cover beneficial ownership of, and transactions in, SEC-registered equity securities.

Beginning in March 2026, directors and officers of “Foreign Private Issuers” (FPIs) will be required to make public EDGAR filings pursuant to Section 16(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) of Forms 3, 4 and 5.  These forms cover beneficial ownership of, and transactions in, SEC-registered equity securities.