Commercial Litigation and Arbitration

Experts — Daubert — Wikipedia Is a Reliable Authority?

Can an expert offer opinion testimony if he or she is relying on Wikipedia, the internet encyclopedia that describes itself as ‛the free encyclopedia that anyone can edit“ ( and ‛an encyclopedia collaboratively written by many of its readers“ ( One might have thought that this open-door policy toward contributions and editing might have rendered the content of Wikipedia suspect, particularly given the occasional brouhaha in the press over phony entries. But maybe those are the exception that proves the rule. The defendants in Alfa Corp. v. OAO Alfa Bank, 2007 U.S. Dist. LEXIS 12771 (S.D.N.Y. Feb. 21, 2007), sought to disqualify an expert for relying on Wikipedia, which the expert described (in this particular area) as highly trustworthy. It turns out that the marketplace of ideas which is Wikipedia is not necessarily suspect. The Alfa Court denied motions to preclude the expert’s testimony which was based in part on Wikipedia, (i) noting that “a recent and highly-publicized analysis in the magazine Nature found that the error rate of Wikipedia entries was not significantly greater than in those of the Encyclopaedia Britannica,“ and (ii) citing several decisions cite Wikipedia as authoritative.

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