Legal Research – Artificial Intelligence (AI)
Legal Issues of the 21st Century
Prof. David Friedman
In my mind, there are two forms of Artificial Intelligences. The first is the computer AI we all are familiar with, which I call the Machine AI. The second is the “uplifted” animal, which achieves full sentience and human level intelligence and communication skills. I have never heard of anyone else making this classification, so for now I will assume that it is my creation.
Obviously, since “science fiction” AI has never actually been invented (to my knowledge, anyway), there is no way that the courts can address the issue of the legal status of an AI. However, several less scifi-ish scenarios have been at least discussed in the legal literature..
What is a Person?
This is a fiendishly difficult topic to research. What I gather is that a person is a modern human—homo sapiens sapiens. The term “person” does not include smart animals or unborn children incapable of surviving outside of their mother’s womb. Intelligence doesn’t have anything to do with personhood as of today. My guess is that the law will, at least initially have laws somewhat like the fictional law proposed by Steven Spielberg in his movie AI: Artificial Intelligence, (2001):
"All sentient artificial constructs, including robots and robotic devices, inanimate devices and structures containing artificial intelligence, and all other sentient inanimate repositories, are deemed to be personal property and shall be governed by common laws and statutory laws addressing personal property. Said property shall have no special rights outside the rights of the given personal property owner."
What is the status of intellectual property developed by a software program?
One current question where we may soon see an answer which might apply to AIs in the future is the question of whether the creator of a software program may claim copyright or patent rights over product of that program’s creativity. Current legal scholarship seems to lean in the direction of a negative answer to that question. It seems clear that the patent statute requires that the person applying for a patent must have actually been the inventor, so if the owner of the program got the idea from outside of his own brain, the argument goes, then he can’t be the inventor. The same goes for copyright. This concept seems quite clear, although the courts don’t always see things my way, so I make no predictions here. The question in the future will be whether a sentient AI who invents something will have the right to obtain a patent or copyright. I believe the answer will turn on whether the constitution covers AIs (are AIs people?) or whether an AI can be an author or inventor.
What are the ramifications of expert system legal advice?
There are quite a few legal software products in the marketplace right now which can provide help with taxes, wills & trusts, divorces, etc. Basically, these programs can do simple tasks, but there is the possibility of analyzing complex legal issues using more complex programs. There is quite a bit of speculation in the field of what needs to be done, and Anne Gardner, a pioneer in the field of case based AI has summarized what she believes is necessary for workable legal AI:
1. the ability to reason with cases and examples, particularly through analogy;
2. the ability to handle ill-defined, open-textured predicates;
3. the ability to handle exceptions;
4. the ability to handle fundamental conflicts between rules; and
5. the ability to handle change and nonmonotonicity.
A method proposed by Gardner (the GP program) is summarized below in pseudocode:
If (there is a tentative answer)
if (there are no "opposite" cases)
then (the case is easy);
but if (there are opposite cases)
if (there are also similarly aligned cases)
then (the law is unsettled and the question is hard);
otherwise (let the technical legal rule override the conflicting CSK [Common Sense Knowledge] rule; the answer is easy).
If (there is no tentative answer)
if(no cases match)
or if (two or more cases match but conflict)
then (the cases fail to resolve the issue and the question is hard);
otherwise (the question is easy and the answer is that indicated by the case(s) that match.
Other examples of case based reasoning can be found at www.cs.umass.edu/~cbr. As of this date, there has been no breakthrough in the legal AI field. Thus, there is no case law on point and it is pure speculation to make any predictions as to where the field will go in the future. I believe that agency law will play a part in how AI legal advice is viewed—i.e. the programmer is responsible for the legal advice that the program gives. This of course assumes that the state bars will allow a program to practice without a license.
Who is responsible for the actions of an autonomous software agent?
There is a project called ALIAS, based out of Vrije Universiteit Amsterdam which aims to study the legal and technical issues that arise from the use of software agents. The project assumes that society will be more likely to accept agent technology if there is a clearly defined legal context. Unfortunately, I could find no cases of anyone litigating over the actions of an autonomous software agent, much less an AI, so once again I have to rely on speculation as to how the courts will rule.
As I see it, there are several ways to look at an AI agent under the current law—the AI is an employee and the user is the employer (respondeat superior), it is a product and the manufacturer is responsible for damages if harm is caused by a defective AI, or the AI is equivalent to a minor or incompetent adult and is incapable of forming a binding agreement. I suppose that the level of intelligence and independence of the particular program will determine the law on a case by case basis, unless some law is passed that requires action one way or another. If the program is self-modifying and acting in an unauthorized manner, it will be difficult to show a chain of causation for damages back to the programmer or owner. If the program is acting under specific orders and follows them to the letter, you would think that the courts will enforce agreements against the employer/owner.
LEGAL RESEARCH FOR VIRTUAL REALITY AND ARTIFICIAL INTELLIGENCE
By Steven Roeser
I tried to approach these subjects under different factual scenarios than previous students so as not to be repetitive in respect to their research.
As previous students’ research explores in detail, the actual technology and programs for virtual reality experiences, as well as the creation process for artificial intelligence, could be protected under intellectual property law: the Copyright Act of 1976, right of publicity, unfair competition, patents. Refer to the course page online.
In the not too distant future, it may be possible for a human being to have a digital clone of oneself(or of a human in general). This clone could conceivably walk, talk, hear, speak, and learn as it spends more time interacting with others. The digital clone could look exactly like it’s living human model so that a living human could not readily tell the difference between the living human and his digital clone. This raises a number of interesting legal issues. What legal rights would this digital clone and/or the creator of this digital clone have if any? Would this digital clone be the property of the creator/consumer, or would it be free to roam and do as it pleases?
The rights of a digital clone would depend on the classification of the clone. This issue turns on what is considered a “person” under current laws. Most sections of the US Constitution contain the word “person” or “people.” There is no definition of a “person” in our legal system and no criteria for determining what constitutes a person. Black’s Law Dictionary defines a “person” as “a human being; the living body of a human being.” It defines an “artificial person” as “an entity, such as a corporation, created by law and given certain legal rights and duties of a human being; a being, real or imaginary, who for the purpose of legal reasoning is treated more or less as a human being.” A digital clone could arguably fall into the category of an artificial person, but even this classification does not guarantee all of the rights guaranteed to a person, but rather “certain” ones.
For example, the Fourteenth Amendment to the US Constitution states “All persons born or naturalized in the US and subject to the jurisdiction thereof, are citizens of the US and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the US; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.” Therefore in order to be a US citizen, a being must be classified as a “person”.
Because the digital clone would be created electronically rather than biologically, under our current legal regime it seems that the clone would not be considered a “person”. Because of the electronic nature of the digital clone, and the fact that it would be created by living persons, it would seem to fall more appropriately in a category of some type of property. If this were the case, the digital clone would not have the rights guaranteed by the Constitution to the people of the United States, such as due process and equal protection.
Could a digital clone be forced to work for the benefit of its creator or owner?
The 13th Amendment states “neither slavery nor involuntary servitude . . . shall exist within the US, or any place subject to their jurisdiction.”
This Amendment makes no mention of a “person”; however, I do not think this would strengthen the digital clone’s argument against being forced to work. US citizens routinely use animals for labor, sometimes against their will, and while a digital clone would be more intelligent than animals as its mental capacity would be tantamount to a living human’s, the digital clone is built from computer technology, and really could be considered a most advanced computer system ever created. Again, this goes to the issue of what constitutes a “person”.
Could an artificial intelligence being have standing to sue? Could a human bring suit against a digital clone?
If a clone of a famous actor was created for someone other than the famous human actor himself, and this clone was then used in movies, the living actor would have legal remedies.
Right of publicity- If a digital clone of a famous person was used in unauthorized ads without the consent of the human famous person, this would violate the human’s right to publicity and damages would be recoverable. unfair business practices
A clone with a unique physical appearance(one that is not modeled after a specific living human) could make defamatory statements about a living human. Could the defamed party then commence an action against the clone in a court of law? In the case of a digital clone identical to a living human, because the digital clone could be mistaken for its living human model, there would be great potential for the clone to commit acts that the public would believe to be committed by the human rather than the clone, or vice versa. For example, if the digital clone appeared on television and defamed another person, many might believe the human was the one who committed the defamatory act rather than the digital clone of the human. This would lead to a scenario whereby the victim of the defamatory statements would want to pursue a cause of action against the human being while the human being may want to commence an action against the clone.
Erwin Chemerinsky, a constitutional law scholar, defines “standing” as “the determination of whether a specific person is the proper party to bring a matter to the court for adjudication.” This includes “artificial persons” as well as corporations and other such entities are often involved in litigation. Again this question turns on the definition of a “person” and whether a digital clone would be classified as such. The scenarios set forth above again seem to suggest that a system of human accountability for digital clones would be likely due to the uncertainty of their behavior and the impact they could have on society if digital clones had the same rights as human persons.
AI/VR AND CRIME
If a human committed a premeditated attack on a digital clone and successfully destroyed the clone, would the attacker be guilty of murder?
Again, because the clone most likely would not be classified as a person, the perpetrator of the crime would not be charged with murder. First degree murder requires a sufficient combination proving planning the murder, a motive to kill, and a sufficient manner of carrying the crime out. While these elements would all be present, because the human attacker intends to destroy a digital clone rather than a human, under our current legal regime the perpetrator would most likely be guilty of a crime against property, such as felony vandalism.
What if the human attacker thought that the digital clone was a specific living human being and intended to kill the human being?
These facts change the scenario drastically as the perpetrator now believes the clone is a human and has the specific intent to kill the human, although the victim ends up being a clone. Attempted murder requires: the specific intent to kill an individual, as well as a sufficient act toward the commission of the offense, clearly present here as the perpetrator believed he was killing the human. The perpetrator would be guilty of attempted murder.
If a virtual reality experience went bad due to an unintentional technical error, such as the person experiencing a severe beating in the virtual reality world, what remedies would be available to the victim?
The victim could sue the inventor, manufacturer and owner of the virtual reality equipment for general negligence, requiring a showing of a general duty of care, breach of that duty of care, proximate causation, and an injury. The victim could also sue for negligent infliction of emotional distress, which requires showing: 1) that the plaintiff was within a zone of danger of physical impact(or reasonably feared for safety regardless of zone of danger in a minority of jurisdictions); 2) the plaintiff must reasonably fear for their own safety; 3) plaintiff must show that they suffered severe emotional distress with attendant physical manifestations. It could be tough to show that P was actually in the zone of danger (in a majority rule jurisdiction) but plaintiff might be able to do so by showing they were jolting violently in response the virtual reality experience.
The victim could also bring a product liability action against the virtual reality unit designer and manufacturer. A design defect product liability action requires a showing that the design was defective, was the actual and proximate cause of plaintiff’s injury, and there was a safer alternate design.
Out current legal system seems well equipped to deal with most problems virtual reality technology poses. However, if and when the time comes where we can create digital clones of ourselves or of humans in general, some new laws will have to be enacted to manage the impact the digital clones would have on our society. A structure of responsibility and accountability for the actions of the digital clones would have to be established, such as putting the weight of responsibility on the shoulders of the creator/owner of the clone. The legal status of a digital clone or artificial intelligence being would have to be changed to a “person” for them to enjoy the same protections as humans, and I do not believe that our society would grant these artificial intelligence beings human status due to the threat they could pose to our society’s structure and the general impact this would have on our society. Living humans would most likely be held responsible for the actions of digital clones that they create or own.
Legal Issues in the 21st Century
Deep VR Legal Research
The first most obvious protection for Deep VR would be under the Copyright Act of 1976:
17 USCS § 106 (2001)
§ 106. Exclusive rights in copyrighted works
Subject to sections 107 through 121, the owner of a copyright under this title has the exclusive rights to do and to authorize any of the following:
(1) to reproduce the copyrighted work in copies or phonorecords;
(2) to prepare derivative works based upon the copyrighted work;
(3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending;
(4) in the case of literary, musical, dramatic, and choreographic works, pantomimes, and motion pictures and other audiovisual works, to perform the copyrighted work publicly;
(5) in the case of literary, musical, dramatic, and choreographic works, pantomimes, and and pictorial, graphic, or sculptural works, including the individual images of a motion picture or other audiovisual work, to display the copyrighted work publicly; and
(6) in the case of sound recordings, to perform the copyrighted work publicly by means of a digital audio transmission.
Any type of VR program, like a computer game or audiovisual work, could be copyrighted in Deep VR. Any infringement would fall under:
17 USCS § 501 (2001)
§ 501. Infringement of copyright
(a) Anyone who violates any of the exclusive rights of the copyright owner as provided by sections 106 through 121, or of the author as provided in section 106A(a), or who imports copies or phonorecords into the United States in violation of section 602, is an infringer of the copyright or right of the author, as the case may be. For purposes of this chapter [17 USCS §§ 501 et seq.] (other than section 506), any reference to copyright shall be deemed to include the rights conferred by section 106A(a). As used in this subsection, the term "anyone" includes any State, any instrumentality of a State, and any officer or employee of a State or instrumentality of a State acting in his or her official capacity. Any State, and any such instrumentality, officer, or employee, shall be subject to the provisions of this title in the same manner and to the same extent as any nongovernmental entity.
(b) The legal or beneficial owner of an exclusive right under a copyright is entitled, subject to the requirements of section 411, to institute an action for any infringement of that particular right committed while he or she is the owner of it. The court may require such owner to serve written notice of the action with a copy of the complaint upon any person shown, by the records of the Copyright Office or otherwise, to have or claim an interest in the copyright, and shall require that such notice be served upon any person whose interest is likely to be affected by a decision in the case. The court may require the joinder, and shall permit the intervention, of any person having or claiming an interest in the copyright.
(c) For any secondary transmission by a cable system that embodies a performance or a display of a work which is actionable as an act of infringement under subsection (c) of section 111, a television broadcast station holding a copyright or other license to transmit or perform the same version of that work shall, for purposes of subsection (b) of this section, be treated as a legal or beneficial owner if such secondary transmission occurs within the local service area of that television station.
(d) For any secondary transmission by a cable system that is actionable as an act of infringement pursuant to section 111(c)(3), the following shall also have standing to sue: (i) the primary transmitter whose transmission has been altered by the cable system; and (ii) any broadcast station within whose local service area the secondary transmission occurs.
(e) With respect to any secondary transmission that is made by a satellite carrier of a performance or display of a work embodied in a primary transmission and is actionable as an act of infringement under section 119(a)(5), a network station holding a copyright or other license to transmit or perform the same version of that work shall, for purposes of subsection (b) of this section, be treated as a legal or beneficial owner if such secondary transmission occurs within the local service area of that station.
(f) (1) With respect to any secondary transmission that is made by a satellite carrier of a performance or display of a work embodied in a primary transmission and is actionable as an act of infringement under section 122, a television broadcast station holding a copyright or other license to transmit or perform the same version of that work shall, for purposes of subsection (b) of this section, be treated as a legal or beneficial owner if such secondary transmission occurs within the local market of that station.
(2) A television broadcast station may file a civil action against any satellite carrier that has refused to carry television broadcast signals, as required under section 122(a)(2), to enforce that television broadcast station's rights under section 338(a) of the Communications Act of 1934
[47 USCS § 338(a)].
As to the content of the program, there would be some dispute as to what could be copied. The best analogy would probably be with motion pictures. A movie can depict an enormous spectrum of content. For example, there are hundreds of movies depicting World War Two. Under the current law, no one would be able to copyright World War Two as their own. Applying this to Deep VR, no one would be able to copyright a specific environment but the original story surrounding the war could be. In movies, these are called “scenes a faire.” Zambito v. Paramount Pictures Corp. 788 F.2d 2. These are basic circumstances that are necessary for the type of movie that one is making. The law would probably follow this type of structure for Deep VR.
Virtual Reality may also bring liability for infringement like the Napster case today. A&M Records v. Napster, 2001 U.S. App. LEXIS 1941 (9th Cir. Cal. 2001). If there is Virtual Reality at home, there could be a system where one could download different programs like music is downloaded on Napster. This leads to the same liability that Napster is facing today along with those who are caught infringing.
Virtual Reality may come up as evidence in the courts, 13 J. Marshall J. Computer & Info. L. 145, VIRTUAL REALITY: THE REALITY OF GETTING IT ADMITTED by Mary C. Kelly & Jack N. Bernstein. This law review talks about the use of VR in the courtroom as evidence. Under the Federal Rules of evidence, 401, evidence is generally considered relevant when it persuades the finder of fact that a fact in controversy does or does not exist. A VR demonstration must indicate that material facts at issue in the case do or do not exist. Since the proponent of the VR demonstration will use testimonial and real evidence from a case to create the demonstration, it will be considered relevant.
Under the existing laws, a doctor and a patient have an confidentiality privilege. Deep VR will most likely be used as a form of treatment in the future. This information couldn’t be used as evidence under the doctor-patient privilege. Liability could result to any doctor who violates that confidentiality.
Virtual Reality presents a tort issue of liability should one get hurt using the VR. General tort law would be essential the same for injuries in VR as they presently are. There would need to be the same elements, of a duty, a breach of the duty, causation, and damages. The makers of the VR program could be held liable under general tort law if these elements were met.
The program makers could also meet some liability for defective products. The general law is that the defect in the product causing the injury was basically an unknown consequence of normal use but foreseeable. If the program should hurt someone because of a defect, and the person was using the product in a reasonable manner, then liability could follow if reasonably foreseeable.
The program makers could also meet some other liability for defamation and unfair competition law. The VR could defame someone and if the elements: 1. defamatory statement; 2. special harm; 3. published to a 3rd party; and 4. fault amounting to negligence, are met, the program makers could be liable. There are defenses to this such as a public figure or newsworthiness.
The VR program makers could be liable under unfair competition if they use a celebrity or likeness in the program. In White v. Samsung Electronics America Inc., 989 F.2d 1512, a television commercial used a futuristic robot that turned a game show letter. Vanna White won the case for the right of publicity. The VR program makers could be liable under this type of case should they use some celebrity or likeness in the program that is sold in commerce.
Virtual Reality could give cause to a medical malpractice action assuming the elements of a tort are met. Doctor’s may likely use VR to perform procedures as practice or a test on a specific person’s problem. If the VR simulation works but the actual procedure fails, it is likely that the doctor could be liable if he or she relied too heavily on the VR program as a test procedure.
Virtual Reality could also be used as for an anesthetic to a patient. If the doctor uses the program improperly, the patient wakes up or a variety of other situations, the procedure would cause the patient harm and under tort law, the doctor could be held responsible if the elements of a tort are met.
Virtual Reality presents a new way to murder someone. If VR is used to kill someone, it would expose one to murder charges of 1st Degree or 2nd Degree. If the killing is negligent, manslaughter could follow or 2nd Degree gross reckless murder.
Virtual Reality could also be used to commit crimes such as burglary. For example, a bank robber could make everyone in the bank see a virtual reality program and rob the bank. There are a variety of statutes that cover all different types of crimes and it would have to be specifically tailored to the situation. The point is, however, that new ways of committing crimes would still fall under a number of different criminal laws already in existence.
Although there are an unlimited number of issues that Deep VR could present, I believe that existing laws would be able to meet such technology. There would obviously be new ways of doing things, such as presenting evidence in the courtroom, but the existing law could handle this technology.
Here are some interesting articles to look up:
PR Newswire, June 15, 1998, Immersive Systems Inc. Produces Virtual Worlds for Psychological Therapy.
The Atlanta Journal and Constitution May 9, 1996, Thursday, DREAM ON; Maybe virtual reality could help solve some of the Earth's very real problems
Legal Issues of the 21st Century
April 22, 2001
Legal Issues and Analysis for Artificial Intelligence
Artificial Intelligence and Intellectual Property
I. Should a machine have patent rights?
- 35 U.S.C. s 102 states “ [a] person shall be entitled to a patent unless…”
- 35 U.S.C. s 101 states “[w]hoever invents or discovers any new or useful process, machine, maunfacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.”
It seems that it is unlikely that a computer or machine can have patent rights unless the definition of a “person” is changed.
II. If you program an AI computer with all the requisite knowledge about, for instance, human anatomy, medicine, chemistry, etc., and it develops a cure, can you own the patent?
- 35 U.S.C. s 102 states “ [a] person shall be entitled to a patent unless…”
subsection (f) “he himself did not himself invent the subject matter sought to be patented,…”
- The inventor is the person who conceived of the specific invention claimed. A person (for example, an employer) who merely directs another (an employee) to solve a problem or make an invention is not an inventor, unless he also told the other how to do it. The provision of subsection (f) does not prevent an inventor from assigning rights in an invention, or to a patent in the invention, to another. However, when such an assignment is made prior to the granting of a patent, the assignee must pursue the application in the inventor’s name.
- from Margreth Barrett, Intellectual Property, p. 36 (1999-2000).
This problem is somewhat complicated since it is unlikely that a computer with AI is seen as a “person” but on the other hand, the person who created the computer and the programs that allowed the computer to invent something, did not himself conceive of the invention. Even if the computer was seen as an “employee” of the person who created the computer program, the person cannot be considered the inventor.
But under 35 U.S.C. s 101, “[w]hoever invents or discovers any new or useful process...” might be construed such that a person using an AI computer as a tool still actually “discovers” something patentable.
III. If you use an AI computer for the purposes of inventing something, what other patent laws might come into play?
A. Non-obvious standard
35 U.S.C. s 103 Conditions for patentability; non-obvious subject matter:
A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102 of this title, if the differences between the subject matter as a whole sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negatived by the manner in which the invention was made.
The Supreme Court in Graham v. John Deere Co., 383 U.S. 1 (1966) held that to make this determination, three factors must be considered: 1) the scope and content of the pertinent prior art; 2) differences between the pertinent prior art; and 3) the ordinary level of skill in the pertinent art.
The use of a computer with AI will undoubtedly affect the standard of a “person having ordinary skill in the art.” If everyone in a particular field began using AI computers to invent things, the standard for what is obvious probably should be raised.
IV. Should a computer with AI have copyrights in works that it produces? For example’s Kurzweil’s Cybernetic Poet could write poetry that was essentially indistinguishable from poetry that actual human poets wrote.
Copyrights protect the expression of ideas rather than the ideas or methods in themselves. Copyright is the traditional form of intellectual property that protects non-utilitarian works such as literature, art, music, and entertainment production in all their genres.
- from Howard Anawalt, Elizabeth Powers, IP Strategy, p. 1-77 (2000)
-17 U.S.C. s 102(a) provides that a copyright subsists “in original works of authorship fixed in any tangible medium of expression, now known or later developed, from which they can be perceived, reproduced, or otherwise communicated, either directly or with the aid of a machine or device.”
-It seems that the poems meet both the originality and fixed medium requirement.
-The term of a copyright is lifetime plus 70 years for works created after January 1, 1978. If an AI computer were to be granted copyrights, then this term is problematic because the term could go indefinitely.
- Section 201 Ownership of Copyright states:
(a) Initial Ownership. Copyright in a work protected under this title vests initially in the authors or authors of the work. The authors of a joint work are co-owners of a copyright in the work.
(b) Works made for hire. In the case of a work made for hire, the employer or other person for whom the work was prepared is considered the author for purposes of this title, and, unless the parties expressly agreed otherwise in a written instrument signed by them, owns all of the rights comprised in the copyright.
- I could not find any language stating that an author is a person. It seems then that a computer, with AI , could possibly have copyright interests under the current copyright laws.
 See David Brin, The Uplift War.
 Hence, no reference to anybody—this footnote just makes my paper look longer.
 I think that courts will be pretty willing to extend personhood to a talking dog or monkey with a human level IQ (say about 100) someday. This is because these animals will be flesh and blood and thereby humans will be able to identify with them. Machine AIs will be a bit different—I think that, at least in the beginning, most people will not be able to empathize with an AI unless it has a biological aspect.
See e.g. Ralph D. Clifford, INTELLECTUAL PROPERTY IN THE ERA OF THE CREATIVE COMPUTER PROGRAM: WILL THE TRUE CREATOR PLEASE STAND UP?, 71 Tul. L. Rev. 1675
 35 USC 102.
 U.S. Constitution, Article 1, § 8, clause 8: “To promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries.”
 Edwina L. Rissland, Book Review: An Artificial Intelligence Approach to legal Reasoning by Anne von der Lieth Gardner, 01 HarvJLTech 223, 226.
 Id. p. 7.
 see fn 4, infra.