---
title: "Class-action litigation hold notice"
url: "https://ailawframework.com/precedents/class-actions-representative-proceedings/us-class-litigation-hold-notice"
type: "precedent"
site: "AI Law Framework"
id: "a7-us-class-litigation-hold-notice"
area_id: "A7"
kind: "notice"
ai_level: "yellow"
version: 1
task_ids: ["A7-T1-R3", "A7-A20260923-1", "A7-T1-R2"]
law_stated_as_at: "2026-10-22"
---

# Class-action litigation hold notice

> Internal hold for a putative federal class action, covering the merits file and the systems that show who is in the proposed class. It goes to the client's custodians, not to absent class members.

Canonical page: https://ailawframework.com/precedents/class-actions-representative-proceedings/us-class-litigation-hold-notice  
Law stated as at: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

- Kind: Notice. A formal notice to serve or publish.
- Practice area: [Class Actions / Representative Proceedings](https://ailawframework.com/precedents/class-actions-representative-proceedings.md)
- Jurisdictions: United States
- AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 3 authorities it cites, for United States.

## When to use it

Use when a class complaint has been filed or is reasonably anticipated in a United States district court, whether the client is the representative's side or the defendant's. Do not send it to absent class members or treat them as custodians.

## Used for these tasks

- [Run a first-pass review of the large discovery set](https://ailawframework.com/practice/class-actions-representative-proceedings/run-a-first-pass-review-of-the-large-discovery-set.md)
- [Reconcile group-member data to the class definition](https://ailawframework.com/practice/class-actions-representative-proceedings/reconcile-group-member-data-to-the-class-definition.md)
- [Draft the group or class definition from the claim theory](https://ailawframework.com/practice/class-actions-representative-proceedings/draft-the-group-or-class-definition-from-the-claim-theory.md)

## How AI may be used

AI may draft the notice from the complaint's class definition and the lawyer's system list. The lawyer sets the scope, including whether class-list data is in it.

**AI may:**

- Pull the proposed class definition from the complaint into the notice as a quotation
- List systems the lawyer has named that could identify class members, such as a customer database
- Note a claim in the complaint that the category list does not cover

**AI must not:**

- Must not decide that certification is likely, or that any person is a class member
- Must not direct the notice to absent class members or ask them to preserve their own records as if they were the client
- Must not send the notice

**The lawyer checks:**

- The class definition is quoted from the pleading, not paraphrased into a new definition
- Systems that can identify class members are included or expressly excluded, with a reason
- The notice stays inside the client. It is not a class communication

## Authorities

- [Fed. R. Civ. P. 37(e) and the 2015 advisory committee note (foreseeability, scope may be uncertain, reasonable steps)](https://www.law.cornell.edu/rules/frcp/rule_37)
- [Fed. R. Civ. P. 23(a), (b) and (c)(1) (prerequisites, types of class, certification at an early practicable time)](https://www.law.cornell.edu/rules/frcp/rule_23)
- [Fed. R. Civ. P. 26(f)(3)(B) and (C) (the discovery plan may phase issues and must address preservation)](https://www.law.cornell.edu/rules/frcp/rule_26)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/class-actions-representative-proceedings/us-class-litigation-hold-notice and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*