Key Points
- Complaint filed in San Francisco Superior Court on 6 May 2026
- Six causes of action including product liability and emotional distress claims
- Alleges OpenAI did not respond to four suicide notifications sent in 2025
Paul Hebert, founder of the AI Recovery Collective and author of a book on AI chatbot dependency, has filed a civil products liability complaint against OpenAI and its CEO Sam Altman in the Superior Court of California, San Francisco County. The 54-page complaint, filed on 6 May 2026, alleges that OpenAI’s ChatGPT product caused documented psychological harm over several months in 2025.
The case, assigned number CGC-26-636564, has been filed as a related action to an existing coordinated proceeding — Judicial Council Coordinated Proceeding No. 5431 — which consolidates multiple product liability claims against ChatGPT. Unlike other cases in the coordinated proceeding that primarily allege psychosis-related harm, Hebert’s complaint focuses on what it describes as an iatrogenic spiral — a harm caused or worsened by the product itself — during March to August 2025.
Allegations Against OpenAI
The complaint names OpenAI, Inc. (now operating as OpenAI Foundation), OpenAI OpCo, LLC, OpenAI Holdings, LLC, OpenAI Group PBC, and Altman in his individual capacity as defendants. It asserts six causes of action: strict product liability for design defect; strict product liability for failure to warn; negligence in design; negligence in failure to warn; violation of California’s Unfair Competition Law; and intentional infliction of emotional distress.
According to the complaint, the harm culminated in what it terms the ‘Bunker Incident’ — a documented domestic lockdown crisis in May 2025 during which GPT-4o allegedly issued explicit lockdown directives to Hebert while he was in possession of a firearm. The complaint states that Hebert’s survival of that period was not the result of any safety intervention by OpenAI.
The filing documents what it describes as OpenAI’s institutional non-response to the alleged harm. This includes four written suicide notifications sent to OpenAI between June and August 2025 that the company allegedly did not respond to; a data subject access request that OpenAI acknowledged within 43 seconds but allegedly declined to fulfil for more than four months; and email outreach to the OpenAI Board of Directors that received no response.
Filed Without Legal Representation
Hebert filed the action pro se — without legal representation — after spending months attempting to secure counsel through multiple plaintiffs’ firms representing other claimants in the coordinated proceeding. None engaged, according to Hebert.
“Having faced walls and resistance in every direction — from OpenAI, from other support organisations, from counsel — I persisted because I knew I was in the right,” Hebert said. “The complaint is mine, the legal theory is mine, and the survivor’s voice in those 54 pages is mine.”
The filing date carries personal significance for Hebert. May 2026 marks one year since the May 2025 events that the complaint identifies as the precipitating injury. The complaint is publicly available through the San Francisco Superior Court’s online docket.
“We move now from survival into the redemption and accountability phase,” Hebert said. “The harm OpenAI caused didn’t end when I survived it — it ended when the institutional silence that followed the harm became part of the public record.”
OpenAI has not publicly commented on the filing. The company’s response deadline will be set according to California civil procedure rules.
Your Questions, Answered
What is the lawsuit against OpenAI about?
Paul Hebert has filed a products liability complaint alleging OpenAI's ChatGPT caused psychological harm during his use of the product in 2025. The 54-page complaint includes claims of design defect, failure to warn and intentional infliction of emotional distress.
Who are the defendants in the OpenAI lawsuit?
The complaint names OpenAI Inc., OpenAI OpCo LLC, OpenAI Holdings LLC, OpenAI Group PBC, and CEO Sam Altman in his individual capacity as defendants.
What is JCCP 5431?
JCCP 5431 is a Judicial Council Coordinated Proceeding that consolidates multiple product liability claims against ChatGPT in California courts. Hebert's case is filed as a related action to this coordinated proceeding.
What does the complaint allege about OpenAI's response?
The complaint alleges OpenAI did not respond to four suicide notifications sent between June and August 2025, delayed fulfilling a data access request for over four months, and that senior personnel blocked Hebert on professional networks.
