Artificial Intelligence (AI) in Mediation – ChatGPT as Mediator 4.0

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ChatGPT – A Revolution in Mediation?

Artificial Intelligence technology such as ChatGPT (GPT-3/4 Algorithm) is considered one of the most groundbreaking innovations of the last decade and has already revolutionized numerous fields, promising efficiency gains and cost reductions. The question that arises in this context is what exactly ChatGPT is. To get a more accurate picture of ChatGPT, we asked ChatGPT itself: „Can you introduce yourself briefly? “.

“I am ChatGPT, a large language model developed by OpenAI based on the GPT-3.5 architecture. My purpose is to provide high-quality, human-like responses to a wide variety of questions and prompts in natural language. I have been trained on a vast corpus of text data, including books, articles, and web pages, and I can answer questions on a wide range of topics, from science and technology to entertainment and culture. I strive to provide accurate and informative responses while also engaging with users in a conversational and friendly manner.”

ChatGPT thus belongs to the so-called generative artificial intelligence (AI) and is part of the broad category of machine learning.^[1] It is an AI-based communication model that has been trained on a large amount of text data and is currently running on GPT-4, which means that ChatGPT now has even direct access to Internet resources.^[2] This architecture, developed by OpenAI, enables ChatGPT to understand, interpret, and respond to natural language. As a result, people feel like they are communicating with computers as if they were people.^[3] Since communication also plays a central role in conflict resolution between people, especially in the context of mediation, the idea of using ChatGPT as an AI-based communication model in this context sounds very promising.^[4] However, the question now is whether and how ChatGPT can be used in the context of alternative dispute resolution, in particular mediation to achieve efficiency gains and cost reductions.

ChatGPT as an AI-based Mediator

In mediation, a mediator assists the parties in reaching a mutual agreement to resolve their dispute. The mediator uses a variety of methods and psychological approaches to facilitate discussion and constructive negotiation between the parties. The mediator’s role is to help the parties identify and understand their own perspectives and needs, as well as those of the other party, in order to reach a mutually agreeable solution.^[5] Not only can these procedures be costly and time-consuming, but the supply is generally far from sufficient to meet demand, especially due to increased disputes following the crises of recent years. As a result, new innovative technologies are needed to make processes more automated and efficient. Of course, this should not be at the expense of quality. ChatGPT offers a promising approach in this regard, as it provides data-driven, objective information and a collaborative environment for dispute resolution.^[6] However, the question is whether ChatGPT is a serious alternative and could possibly even replace a human mediator, or whether it should rather be used by a mediator as a support tool. This will be explored below based on the typical skills of a mediator.

Communication Skills for Independent Mediation

Mediation basically takes place in a one-on-one conversation with the parties involved. The first hurdle to consider when using ChatGPT as a mediator is whether the AI is capable of independently conducting a mediation on a linguistic level, interacting with the parties, identifying contexts, and providing conflict resolution direction.

Since ChatGPT is a generative AI trained on natural language models, it can articulate itself while sounding fluent and convincing.^[7] But that’s not all: the AI is also able to remember user input and recognize context, so it can carry on a conversation on its own.^[8] In combination with the new AutoGPT and AgentGPT features in GPT-4, the AI can even be given a conversation goal to orient itself to. Thus, ChatGPT is theoretically capable of not only responding to input from the parties, but also steering a conversation in a conflict-resolving direction.^[9]

Processing and Filtering of Big Data

In addition to language skills, one of the major advantages of ChatGPT over a human mediator is the AI’s apparent ability to process and analyze a large amount of information efficiently and quickly. The mediator is essentially limited to his or her experience from similar disputes in previous mediations and the theoretical knowledge that he or she accumulates over time.^[10] Due to the innovations in ChatGPT-4, the AI can now also access the Internet and thus real-time data. It is no longer even limited to an additional imported set of data and updates. As a result, ChatGPT has a huge amount of up-to-date data at its disposal that it can undoubtedly retrieve faster than a human ever could.^[11]

With self-supervised learning, AI can identify potential solutions, patterns, and trends even more easily than a traditional mediator. When presented appropriately by ChatGPT, these insights can help to better understand the underlying conflict issues and explore a range of resolution options.^[12]

It is necessary for ChatGPT to store user data to identify the context and conduct the conversation. This, of course, raises privacy concerns that need to be addressed, particularly considering the confidentiality requirements of a mediation. Therefore, prior to using ChatGPT, it should be determined in consultation with the parties what data will be collected and stored by the AI during the mediation.^[13]

On the other hand, ChatGPT is limited and dependent on the data sets available to it. If these resources contain errors, such as incorrect information or bias, ChatGPT not only cannot detect them on its own, but would actually base its responses on them.^[14]

After all, the performance of ChatGPT still depends on the person using it. In this context, it is especially important to ask the “right” question, because only then can ChatGPT provide a reliable response.^[15] Of course, the AI’s output always depends on the user’s input. Sometimes more information is needed to recognize the context. Since this requires special training or knowledge, it would be beneficial not to leave the parties to their own devices, but to use mediators who are specially trained to ask the right questions.^[16] However, this also means, by implication, that ChatGPT should only be used by trained mediators with appropriate skills who review ChatGPT results before providing them to the parties. In this way, the risk of misunderstandings and inadequate responses can be avoided, which can even lead to stalemate between the parties in a mediation.^[17]

The Bias of The Human Mediator

Another advantage of ChatGPT is that, unlike human mediators who can be consciously or subconsciously influenced by external factors, AI-based tools provide an objective and neutral view, which is especially important regarding the mediator’s impartiality. This impartiality can build trust between the parties in using ChatGPT as a neutral AI-based mediator and provide a good basis for settlement. On the other hand, however, there are also concerns that ChatGPT is not completely free of bias or even discrimination.^[18] AI is mostly based on statistics, more precisely probability calculation. Depending on its data sets, ChatGPT’s responses may be based on gender, racial, and myriad other biases of the internet and society.^[19] By changing the context, the statements can even be manipulated.^[20] Consequently, ChatGPT does not appear to be entirely independent after all.

Empathy, Emotions and Cultural Differences:

Moreover, there are reasonable doubts about the ability of an AI like ChatGPT to show empathy for the parties.^[21] However, empathy is an important resource for mediators and can be considered as the “soul of mediation”. Not only does it help the mediator to better understand the parties, but it also reduces the emotional pressure on the participants. In the context of dispute resolution, it is often important for the parties to be heard and understood before there is any willingness to negotiate.^[22]

At the same time, empathic accuracy is a very challenging and difficult skill to learn.^[23] An essential requirement for empathy is the ability to understand and classify emotions in the first place. But as an AI, ChatGPT typically lacks the emotional intelligence that humans possess.^[24] While ChatGPT can generally explain emotions in terms of how they affect human behavior and conflict situations, ChatGPT itself has no emotions or feelings.^[25] At the same time, ChatGPT, at least so far, does not have direct access to body language data such as gestures and facial expressions, which makes it even more difficult to recognize the emotions of the parties.^[26] However, because AI can only infer emotions from verbal conversations and not from body language, it is not always able to recognize human emotions. In addition, it does not always have the ability to understand them in the context of a particular argument. For example, cultural factors, which are often at the root of emotional conflicts, especially in the context of international disputes, are regularly at play and cannot be recognized and thus addressed by the AI. This makes it particularly difficult for ChatGPT to identify underlying interests.^[27]

Ethical And Legal Issues

The use of AI technology in mediation naturally raises some ethical and legal issues that need to be addressed, such as whether and to what extent ChatGPT respects laws and social values.^[28]

Based on these legal and ethical issues, there are several additional criteria that should be considered when ChatGPT completely replaces a human mediator. For example, autonomy and control is a criterion that should be examined more closely. To what extent is an effective and self-determined use of AI possible at all?^[29] Furthermore, especially for the purposes of mediation, it is important to clarify whether ChatGPT treats all parties fairly.^[30] But the criterion of fairness is a very subjective one, which makes it necessary to deal with the principle of transparency. Therefore, it should always be possible to understand exactly how ChatGPT arrived at its decisions.^[31] But there is also the question of reliability and manipulability of ChatGPT. Is the AI secured against errors, accidents, and attacks and finally, is privacy protected?^[32] These are just a few of the questions that need further investigation.

Interim Conclusion

Because of all these criteria, it is important to ensure that AI like ChatGPT is used ethically, legally, and responsibly. It is necessary that the use of AI is not only regulated, but also monitored.^[33] Therefore, it can be doubted whether ChatGPT can be considered as a stand-alone mediator. ChatGPT as an AI does not fully understand emotions and consequently is not able to understand the perspective of the conflict parties or to show empathy and support them emotionally.^[34] In addition, there are still too many unresolved ethical questions that need to be answered. Without appropriate guidelines, an AI cannot be fully equated with a mediator, even with further development of ChatGPT.^[35]

This opinion was also shared by ChatGPT itself when the AI was asked if it could replace a human mediator: “As an AI language model, I can provide information and suggestions based on data and algorithms, but I cannot replace the role of a human mediator. A mediator is a trained professional who helps parties in conflict to reach a mutually agreeable solution. A mediator often relies on a combination of communication skills, active listening, empathy, and the ability to recognize and address power imbalances to help people in dispute find common ground. While I can provide general information on conflict resolution, I cannot replace the human qualities that a mediator brings to the process. Mediation often involves emotional intelligence, which is an area where AI models like myself still have limitations. “

ChatGPT As A Mediation Tool

However, the advantages offered by ChatGPT should not remain unused. One possibility would be to use ChatGPT as a support tool for the mediator, an AI assistant so to speak, in the context of mediation as augmented and assisted intelligence.^[36] The question that arises in this context is how exactly can ChatGPT support the human mediator during a mediation and to what extent is it possible to achieve synergy effects through this collaboration?

Providing Information and Documentation

ChatGPT can provide the mediator with relevant information about the various elements of conflict management and resolution related to the conflict to assist in the mediation process. Unlike many other search platforms, ChatGPT as an AI assistant can help to search for specific resources and information and then provide them in a structured and understandable way.^[37] In addition, ChatGPT can also respond to specific questions and needs of a user and thus answer individual questions of the mediator. The advantage here is that ChatGPT processes the information in a comprehensible and structured way and can also provide the sources.^[38]

Finally, by generating transcripts of the parties’ conversations, which may not be permitted in many mediations because of confidentiality, ChatGPT can provide documentation of the mediation process, which helps the mediator keep track of progress.^[39]

Generating Solutions

Furthermore, ChatGPT can generate potential solutions to the conflict, which can be especially effective when brainstorming is necessary. The generated solutions can then be considered by the mediator during the mediation process. However, AI can also be used by the parties even before the mediation to brainstorm or optimize creative solutions.^[40]

Providing Insights

In addition, the AI can provide insights into the interests and perspectives of the parties to a conflict, which can help the mediator understand the underlying causes of the conflict.^[41] Therefore, ChatGPT can formulate questions that may be helpful in a mediation situation to support a particular mediation style. For example, the AI can provide questions that ask for the perspectives of the parties to the conflict, to understand them better, and to allow them to express their interests, needs, and feelings appropriately.^[42] ChatGPT can also formulate questions aimed at developing proposed solutions and alternatives. Then, depending on the context and the needs of the parties, the mediator can choose from a catalog of questions.^[43]

Offering Communication Tool

ChatGPT can offer communication tools that can be used by the mediator to facilitate communication between the parties involved in order to find a solution that is acceptable to all parties. Thus, the AI provides the mediator with resources and information to help the mediator do his or her job efficiently and successfully. For example, ChatGPT can show different conflict resolution strategies and techniques, prepare materials for mediation and negotiation, and many other tips and tricks.^[44]

Symbiotic Relationship – Mediator and AI

It is also conceivable that the AI’s ability to statistical learning from the mediator’s questions and approach over time will allow it to optimize and adapt to the mediator.^[45] Since ChatGPT has been trained on an enormous amount of text data, there is evidence that ChatGPT can also store and learn from the mediator’s input. Based on these additional resources ChatGPT can uncover correlations, analyze the mediator’s approach and goals, and help him or her become even more efficient in finding the most capable solution for the disputants.^[46] In the long run, this learning mechanism could bring ChatGPT closer and closer to the goal of acting as a stand-alone mediator. However, while generative AIs like ChatGPT can appear creative because of the amount of data they are trained on and have available when performing tasks, they are still not intelligent and depend on human input, as they are only capable of reframing sentences based on the data set.^[47]

Not only can the AI learn from the mediator, but the mediator can also learn from the AI. ChatGPT has the ability to monitor progress, evaluate the mediation process, provide feedback on the mediator’s techniques, and evaluate and document the outcome of the mediation.^[48] ChatGPT can also provide recommendations on how the mediator can improve his or her performance in future mediations.^[49] This creates a symbiotic learning relationship between the mediator and the AI that should not be left untapped.

First practical inquiries

Various areas of application are conceivable here. For example, ChatGPT could be used to prepare a mediator’s opening statement in a contract dispute, to propose and brainstorm solutions for concrete disputes and much more.

However, these considerations are not purely theoretical. In fact, there are already cases of first use in practice. For example, ChatGPT was recently used by Myer Sankary, an experienced mediator, in an online mediation that resulted in a settlement. In this contract dispute involving the wrongful termination of a lease, the landlord sought payment of $550,000 from the guarantor. The guarantor offered $120,000. Eventually, an impasse was reached, and the mediator prepared a possible mediation proposal.  However, he was not sure what number to propose. So, Mr. Sankary quickly entered the offer and demand, along with the likely outcome in favor of the landlord if a trial were held. However, a number that would be acceptable to both parties had to be chosen. After providing some algorithms, the AI suggested that a fair settlement would be $275,000. This was more than the mediator thought the tenant would be willing to pay. The mediator informed the attorneys about using ChatGPT to announce a fair settlement amount without revealing the number unless they reached an impasse. Through further negotiations, the tenant offered $270,000, and to the mediator’s surprise, the landlord accepted.

After the settlement agreement was signed, the attorneys wanted to know what ChatGPT recommended.  The landlord, of course, thought he should have held out for more, but was satisfied.  Even though the tenant had a significant loss, he was happy to have gotten a fair settlement under the circumstances (after weighing the legal expenses going to trial and risking a larger judgment.)

What can be concluded from this practical example is that ChatGPT was an interesting, efficient, and useful tool to obtain an objective evaluation to support the settlement.  It was useful information for the mediator to increase his confidence in the negotiated figure, which was within a range of plus/minus acceptable outcomes. Although as an experienced mediator, without AI there might have been serious doubts about proposing $275,000 as a fair settlement amount. AI’s response bolstered the mediator’s confidence in the final settlement amount.  Knowing that the mediator had received a number from AI may also have encouraged the parties to agree to the final number. We urge caution, however, to carefully consider the prompts that are used so as not to get a biased outcome.  It is also possible that a different number may have been suggested by regenerating the prompt or by changing the prompt input.  Remember “garbage in, garbage out.”

Conclusion

In conclusion, ChatGPT-4 has the potential to significantly change the field of mediation by providing low-cost, effective, and objective mediation information as an AI-based tool. This will assist the mediator to find alternative viable solutions for the parties involved.^[50]

However, it is important to always maintain a balance between the ethical concerns associated with the use of AI and the capabilities of AI. Accordingly, mediation based entirely on AI does not seem feasible at this stage.^[51] Instead, a human mediator should continue to conduct the mediation, but integrate the above-mentioned benefits of ChatGPT into mediations.^[52] Through this human-AI interaction, great synergy effects can be exploited, which not only helps the mediator to work more efficiently, but can also significantly speed up the process and increase the chances of a possible settlement that satisfies the parties. Such interaction can ensure that technology is used as a supportive tool for peace and understanding in our increasingly technological world.^[53]

For more information, please contact Christoph Salger at [email protected] or Sonja Weisheit at [email protected]  For Mr. Sankary use [email protected] .

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^[1] Manuel Lamiroy, ChatGPT for Lawyers, Lamiroy Consulting Blog (January 25, 2023; last access: April 15, 2023), https://www.lamiroy.com/blog/chatgpt-for-lawyers/.

^[2] Hossein Hassani & Emmanuel Sirmal Silva, The Role of ChatGPT in Data Science: How AI-Assisted Conversational Interfaces Are Revolutionizing the Field, MDPI (March 27, 2023; last access: April 02, 2023), https://www.mdpi.com/2504-2289/7/2/62.

^[3] Id.

^[4] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.

^[5] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[6] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.

^[7] Manuel Lamiroy, ChatGPT for Lawyers, Lamiroy Consulting Blog (January 25, 2023; last access: April 15, 2023), https://www.lamiroy.com/blog/chatgpt-for-lawyers/; Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[8] Manuel Lamiroy, ChatGPT for Lawyers, Lamiroy Consulting Blog (January 25, 2023; last access: April 15, 2023), https://www.lamiroy.com/blog/chatgpt-for-lawyers/.

^[9] Gary Doernhoefer, Artificial Intelligence and Dispute Resolution: A Primer and Opportunity for the Future, ADR Notable (March 21, 2023; last access: March 23), https://www.adrnotable.com/ai-primer/.

^[10] James Melamed, Optimization in Mediation and Artificial Intelligence, mediate.com (April 11, 2023; last access: April 09, 2023); https://mediate.com/optimizing-ai-in-mediation/.

^[11] Sebastian, Auto-GPT & AgentGPT: The Groundbreaking AI Innovations You Need to Know, Medium (April 16, 2023; last access: April 22, 2023), https://medium.com/codingthesmartway-com-blog/auto-gpt-agentgpt-the-groundbreaking-ai-innovations-you-need-to-know-cc7820463d4b.

^[12] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[13] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.

^[14] Manuel Lamiroy, ChatGPT for Lawyers, Lamiroy Consulting Blog (January 25, 2023; last access: April 15, 2023), https://www.lamiroy.com/blog/chatgpt-for-lawyers/.

^[15] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/; Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[16] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[17] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[18] Manuel Lamiroy, ChatGPT for Lawyers, Lamiroy Consulting Blog (January 25, 2023; last access: April 15, 2023), https://www.lamiroy.com/blog/chatgpt-for-lawyers/.

^[19] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[20] Id.

^[21] John Lande, AI and Empathy, indisputably (February 26, 2023; last access: April 25, 2023), http://indisputably.org/2023/02/ai-and-empathy/. 

^[22] Sarathi Susheela, Empathy in Mediation, mediate.com (Mai 17, 2023; last access: April 14, 2023); https://mediate.com/empathy-in-mediation/.

^[23] Marcin Frąckiewicz, ChatGPT for Sign Language Translation: Advancements and Challenges, ts2 (April 24, 2023; last access: April 25, 2023), https://ts2.space/en/chatgpt-for-sign-language-translation-advancements-and-challenges/.

^[24] Cloudmayo, 7 Reasons to Use ChatGPT (& 5 Reasons You Shouldn’t), cloudmayo (April 05, 2023; last access: April 20, 2023), https://www.cloudmoyo.com/blogs/7-reasons-to-use-chatgpt-5-reasons-you-shouldnt/.

^[25] Kris Hartung, Can ChatGPT exhibit emotional intelligence? (Part I), LinkedIn (April 18, 2023; last access: April 25, 2023), https://www.linkedin.com/pulse/can-chatgpt-exhibit-emotional-intelligence-part-i-kris-hartung.

^[26] Marcin Frąckiewicz, ChatGPT for Sign Language Translation: Advancements and Challenges, ts2 (April 24, 2023; last access: April 25, 2023), https://ts2.space/en/chatgpt-for-sign-language-translation-advancements-and-challenges/.

^[27] Id.

^[28] Louis Byrd, Ethical evolution in the age of AI: why fear and complacency are not options, Medium (April 7, 2023; last access: April 22, 2023), https://uxdesign.cc/ethical-evolution-in-the-age-of-ai-why-fear-and-complacency-are-not-options-2f8fd35eec16.

^[29] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[30] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[31] Marcin Frąckiewicz, The Challenges of Ensuring Fairness and Diversity in ChatGPT Prompt Generation and Selection, ts2 (April 24, 2023; last access: April 25, 2023), https://ts2.space/en/the-challenges-of-ensuring-fairness-and-diversity-in-chatgpt-prompt-generation-and-selection/.

^[32] Mohamed Al Husrom, Uncovering the Hidden Risks of ChatGPT: Keeping Your Data Secure, Medium (December 27, 2022; last access: February 28, 2023), https://medium.com/nextray-ai/uncovering-the-hidden-risks-of-chatgpt-keeping-your-data-secure-99911f3ed777; Louis Byrd, Ethical evolution in the age of AI: why fear and complacency are not options, Medium (April 7, 2023; last access: April 22, 2023), https://uxdesign.cc/ethical-evolution-in-the-age-of-ai-why-fear-and-complacency-are-not-options-2f8fd35eec16.

^[33] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[34] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.

^[35] Louis Byrd, Ethical evolution in the age of AI: why fear and complacency are not options, Medium (April 7, 2023; last access: April 22, 2023), https://uxdesign.cc/ethical-evolution-in-the-age-of-ai-why-fear-and-complacency-are-not-options-2f8fd35eec16.

^[36] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[37] Marcin Frąckiewicz, ChatGPT-4 and Alternative Dispute Resolution: Exploring AI’s Role in Mediation and Arbitration, ts2 (April 12, 2023; last access: April 20, 2023), https://ts2.space/en/chatgpt-4-and-alternative-dispute-resolution-exploring-ais-role-in-mediation-and-arbitration/.

^[38] Shivbhadrasinh Gohil, ChatGPT vs Google: Is ChatGPT Going to Replace Google? Meetanshi Blog (April 24, 2023; last access: April 25, 2023), https://meetanshi.com/blog/chatgpt-vs-google/.

^[39] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/; Molly Ruby, How ChatGPT Works: The Model Behind the Bot, Medium (January 30, 2023; last access: March 28, 2023), https://towardsdatascience.com/how-chatgpt-works-the-models-behind-the-bot-1ce5fca96286.

^[40] James Melamed, Optimization in Mediation and Artificial Intelligence, mediate.com (April 11, 2023; last access: April 09, 2023); https://mediate.com/optimizing-ai-in-mediation/.

^[41] Marcin Frąckiewicz, ChatGPT-4 and Alternative Dispute Resolution: Exploring AI’s Role in Mediation and Arbitration, ts2 (April 12, 2023; last access: April 20, 2023), https://ts2.space/en/chatgpt-4-and-alternative-dispute-resolution-exploring-ais-role-in-mediation-and-arbitration/.

^[42] Id.

^[43] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[44] Molly Ruby, How ChatGPT Works: The Model Behind the Bot, Medium (January 30, 2023; last access: March 28, 2023), https://towardsdatascience.com/how-chatgpt-works-the-models-behind-the-bot-1ce5fca96286.

^[45] Sebastian, Auto-GPT & AgentGPT: The Groundbreaking AI Innovations You Need to Know, Medium (April 16, 2023; last access: April 22, 2023), https://medium.com/codingthesmartway-com-blog/auto-gpt-agentgpt-the-groundbreaking-ai-innovations-you-need-to-know-cc7820463d4b.

^[46] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[47] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/.

^[48] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/; Waterhouse Mediation, Can ChatGPT be used to train mediators? Waterhouse Mediation (last access: April 21, 2023), https://waterhousemediation.com.au/uncategorized/can-chatgpt-be-used-to-train-mediators/.

^[49] Waterhouse Mediation, Can ChatGPT be used to train mediators? Waterhouse Mediation (last access: April 21, 2023), https://waterhousemediation.com.au/uncategorized/can-chatgpt-be-used-to-train-mediators/.

^[50] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.

^[51] Robert Bergman, ChatGPT and Mediation, mediate.com (February 10, 2023; last access: April 14, 2023), https://mediate.com/chatgpt-and-mediation/; Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[52] Kenneth Cloke, Mediation, Artificial Intelligence and ChatGPT, mediate.com (January 08, 2023; last access: February 13, 2023), https://mediate.com/mediation-artificial-intelligence-and-chatgpt/.

^[53] Marcin Frąckiewicz, ChatGPT-4 for Conflict Resolution: AI-powered Mediation and Negotiation, ts2 (April 12. 2023; last access: April 04, 2023), https://ts2.space/en/chatgpt-4-for-conflict-resolution-ai-powered-mediation-and-negotiation/.