The buzzword in all of technology right now—including legal technology—is AI, especially generative AI, which can take one set of information and use it to create new information. When ChatGPT was introduced last year, people were amazed at how quickly it could provide complex answers to all sorts of different types of questions, albeit sometimes with mistakes. The new AI feature introduced a few weeks ago in Westlaw is impressive and has already made a noticeable difference in my law practice. As Microsoft, Google, Apple, and so many others are looking at what can be done with generative AI, some iPhone and iPad apps are starting to incorporate AI in interesting ways that show a lot of promise. Today, I am discussing recent updates to two of the most useful iPad apps in my law practice: Readdle's PDF Expert and GoodNotes. The recent addition of AI to these apps has made them much more useful to attorneys and other professionals for whom it is helpful to quickly get information from a document.
AI Chat in PDF Expert
The PDF Expert app from Readdle is a fantastic app for storing, reading, and annotating PDF documents. The new AI Chat feature in PDF Expert is still in beta, and it is only available if you have a premium subscription. To use the feature, in the PDF Expert app on the iPad (or iPhone or Mac), open up a PDF document that has readable text. (If your PDF document only contains an image of the document, you'll first need to OCR the document, which is a feature available in PDF Expert on the Mac but not yet on the iPad/iPhone.) At the top right of the screen, next to the search icon (a magnifying glass), you will see an icon containing a word bubble with the letters AI in it. Tap that button, and the app will analyze your document.
The app next suggests some quick actions that it can do using AI: Generate Summary, List Main Points, Generate Keywords, and Generate Hashtags. You can tap Generate Summary to find out what a document is about without taking the time to read the document.
In some of my tests, the Generate Summary feature was quite useful and accurate. Other times, it was accurate but not very useful. For example, when I asked it to summarize an opponent's appellate brief in one of my cases, this is what I saw:
The summary, provided in the right column, says: "The document is an original brief of appellee [name] in a civil action case. It provides a summary of the argument and statement of the case, as well as the legal arguments and standards of review. It also includes a table of contents and table of authorities. The document discusses the abuse of discretion standard of review and argues that the district court did not abuse its discretion in sanctioning [party] for its discovery failures and repeated misrepresentations. It cites several cases to support its arguments and concludes by stating that the district court's choice of sanctions was reasonable and appropriate." Technically, that summary is accurate, but only a single sentence really tells me anything about the substance of brief. Being told that a legal brief contains a table of contents and table of authorities and discusses the standard of review is not helpful. But again, for other documents, the Generate Summary and related List Main Points options gave me something useful without me needing to take the time to read the document.
More interesting is the ability to Ask Anything. Imagine that you gave a document to another person and that person studied and memorized the document. Next, imagine asking that person a specific question about the document. This is useful because that person could immediately tell you the answer, saving you the time of reading through the entire document yourself.
For example, in preparing for one of my appellate oral arguments a few weeks ago, I had reviewed lots of different prior opinions in other cases. When I look at the Jones case again, was that the one with fact pattern X or the one with fact pattern Y? With this new AI feature in PDF Expert, I can open up one of the opinions that I downloaded from Westlaw and just ask a question. For example, in a case in which the Louisiana Supreme Court held that a trial court erred in not granting a continuance, I asked: "What was the basis for seeking a continuance." In just a second, the app told me specific facts set forth by the plaintiff to support a continuance (his physical and emotional condition) and the evidentiary support provided (a doctor's note saying that the plaintiff needed another three months). This instantly reminded me what this case was all about.
Using AI to ask a question about a document is somewhat similar to using the search feature to find a keyword in a document. But it is much more powerful because you can use natural language to explain what you are looking for instead of using a precise term in a traditional search that might not be found because the document used a synonym or the word in a different tense or something like that. And sometimes, you are not exactly sure what you are looking for, so you may not know what term to search for even though you know the concept that you are interested in.
One of the big dangers of relying upon generative AI is hallucinations. An AI bot might sometimes give you an answer with the complete confidence of somehow who knows what he is talking about and yet the AI is completely wrong. Thus, whenever you get any sort of answer using AI, it is critical to confirm the answer that was provided. PDF Expert helps you do this by telling you the page(s) of the document from which the answer was generated. For example, in the example above where I asked a question about a Louisiana Supreme Court opinion, I can see that the answer came from page 5. By jumping to page 5, I can see (1) the actual text of the opinion that resulted in the answer and (2) that the AI actually pulled the answer from a dissent, not the majority opinion. For this type of question, none of that was a problem for me. The text of the document supported the AI's answer, and even though the AI was relying on the dissent, both the dissent and the majority were looking at the same facts. But you can certainly imagine a situation in which you ask a question about a legal holding in a case and if the AI pulls its answer from the dissent, the answer might be 100% wrong.
My experience using the beta version of this AI feature in PDF Expert parallels my experience with AI in general. The AI is not always correct, so after you read the answer provided by the AI it is critical that you next double-check the answer in the text. But because the AI is usually correct, and because it is so fast and can answer such complex questions, I still tend to be better off after using AI than I would have been without it because the AI helps me to quickly get to the relevant portion of the document. As the developer of PDF Expert says on its website, this new AI feature can be very useful for some legal professionals because "[y]ou can use AI Chat to locate specific clauses or reference points with lengthy legal documents without the need to read them thoroughly." I agree with that completely.
Ask GoodNotes
GoodNotes is the app that I use to take handwritten notes. Over time, some of my digital notebooks can become dozens of pages long, sometimes over 100 pages. Fortunately, the app can read handwriting, so if I want to find a specific word that I previously used in a note, I can search for the word and see the pages containing that specific word.
But as noted above, sometimes a word search is too precise. With the new Ask GoodNotes feature, which the developer says is still in an experimental stage, you have new AI tools for getting information from your documents.
First, you can summarize an entire document or (for longer documents) a range of pages. In my tests, the summaries have been pretty accurate and helpful. If you have 10 pages of notes from a meeting, GoodNotes can quickly give you six bullet points that sum up your meeting. If you had taken the time to do the same thing, perhaps you would have added a seventh or eighth bullet point, but it would take you significant time to put that together. GoodNotes does a decent job in just seconds.
Second, the Q&A feature lets you ask a question about your notes. Just like in PDF Expert, it can be far more helpful than a simple word search, and you are provided with the specific page numbers of your notes that were used to come up with the answer so that you can go back and double-check everything.
In the following example, I ran of search of notes that I had previously taken in meetings of my law firm's technology committee, a committee that I chair. I was curious about the companies that we had used in the past to run a penetration test, a way to check the security of a network. So I took my handwritten notes from our meetings and searched for terms like "pen test" and "penetration test" and I was able to find some of my notes about companies that we had used in the past. Then I asked the AI to do a similar search and it came up with its own answers. Moreover, after giving me the answer, the AI suggested some follow-up questions that I may want to ask.
Note that in addition to working with handwritten notes, GoodNotes can also work with any PDF file. Thus, I sent the same Louisiana Supreme Court opinion that I had analyzed in PDF Expert to GoodNotes. Then, I used the AI Q&A feature to ask the same question: "What was the basis for seeking a continuance." In just a second, GoodNotes responded: "The basis for seeking a continuance was the illness of one of the plaintiffs who had undergone an arterial transplant and whose testimony was considered critical to the case." The cite provided was to page 1 of the case, so unlike PDF Expert which gave me a more complete answer by citing the dissent, GoodNotes gave me a shorter but still precise answer by pulling information from the Westlaw headnote on the first page of the opinion. GoodNotes also gave me some good suggestions for follow-up questions, such as "Was any previous continuance requested in the case?"
That was a smart question to ask because the holding in that case was not only based upon the reason for the continuance request but also the fact that this would have been the first requested continuance by the plaintiff in the case. One of the things about generative AI (in general) that I particularly like is that it can often help you to think of important concepts that might not have occurred to you at first. By suggesting additional questions, GoodNotes can help you to think about important, related concepts. Sometimes, that can be incredibly helpful.
The AI Q&A feature of GoodNotes is yet another way to get out information in your own notes. Just like a simple word search, it may not give you all of the answers, but it can be a useful tool.
Information privacy
About a year ago, when ChatGPT and similar generative AI products first rose to predominance, people noticed that if one person provided certain information in forming a question, ChatGPT might remember that information and use the same information when providing an answer to someone else's question. This led many legal ethics professionals (here is an example) to note that lawyers need to protect the confidentiality of certain information and to warn that providing confidential information to a generative AI system could be a breach of that duty.
I reached out to the developers of both of these apps to ask about whether using generative AI on my documents or notes means that the contents are shared with third-parties and become a part of the generative AI engine. In both cases, I was told that this does not happen. Here is what Readdle said about PDF Expert:
[W]e process each of your requests in the AI Chat in 3 steps. First, we receive and pseudonymize your request.
Second, we send it to OpenAI, L.L.C. (OpenAI) infrastructure for processing.
Third, we receive the output from OpenAI and provide the result back to you. Please note that we do not control or influence the data included in your requests, their results, or the associated files. OpenAI processes your requests according to their Business Terms, Privacy Commitments, and Data Processing Addendum. Among other things, they commit not to use the data for training and retain API inputs and outputs for up to 30 days to identify abuse only.
Additionally, both your request and its results are encrypted in alignment with our standard privacy and information security practices. We employ the latest commercially reasonable technical, administrative, and organizational measures to safeguard your personal data, both online and offline, against loss, misuse, unauthorized access, disclosure, alteration, or destruction. For further insights into your privacy within PDF Expert, please refer to our Privacy Notice.
Here is what the developer of GoodNotes told me:
Goodnotes assures users that it does not access or collect data from their notebooks to train its AI features. However, users of Goodnotes can voluntarily submit their data through 'Feature Feedback' under section 3.7.1. Goodnotes may use this information to improve its services, but only if it is submitted voluntarily. ... Goodnotes takes its customers' data seriously. We want to reassure our users that GoodNotes does not have access to their notes or the information, whether they are saved in local or iCloud storage or third-party cloud services (i.e. OneDrive). Your personal notes remain private and are not shared with third parties.
For a much deeper breakdown of all this, please see: GoodNotes Privacy Policy / GoodNotes Terms and Conditions.
As generative AI continues to get more sophisticated, I suspect that privacy will become even more of a concern, so this is something to always consider when you use any of the AI systems coming on to the market.
Limited use
Running generative AI searches can be costly for app developers, so both PDF Expert and GoodNotes limit how much you can use these new generative AI features. It looks like PDF Expert currently limits you to 200 searches a month. A number at the top left of the Chat pane tells you how many searches you have left. GoodNotes currently limits you to 30 credits (30 questions) each day.
Conclusion
The developers of PDF Expert and GoodNotes say right up front that these generative AI features are currently in their preliminary stages. Nevertheless, I have already found them to be useful in my law practice. Considering how useful they are at this early point, I'm incredibly excited about the possibilities as this technology is further refined in the future.
As someone who works with lots of different types of documents every single day, I love the idea of my iPad or iPhone helping me to get information from my documents faster than ever, not to mention helping me to see things in my documents that I otherwise might have missed. Don't forget the crucial step of verifying any answers that are provided by the AI. But even with that caveat, generative AI assistance can be incredibly useful, and as more lawyers and other professionals learn to take advantage of this emerging technology, you won't want to be left behind.
