When a machine decides which firms to name, what is it reading? The question has an answer, and it is better documented than most people in legal marketing realize.
The most rigorous public study comes from researchers at the University of Toronto, published in September 2025. They ran 1,000 consumer questions of the kind people ask when choosing who to hire, across four AI systems and Google, then classified every source each system cited into three buckets.
Brand meant the company’s own website. Earned meant independent third parties: news outlets, trade press, review and comparison sites. Social meant forums and user-generated content, principally Reddit and Quora.
Here is what the systems cited when asked about well-known companies.
| System | Earned | Brand-owned | Social |
|---|---|---|---|
| ChatGPT | 93.5% | 6.5% | 0% |
| Claude | 87.3% | 6.8% | 5.9% |
| Perplexity | 67.4% | 8.8% | 23.8% |
| Gemini | 63.4% | 25.1% | 11.5% |
Google’s own search results, run against the same questions, produced close to the opposite pattern. The company’s own website dominated, with earned media second.
When a person asks Google, they get sent to your website. When they ask ChatGPT, your website supplies roughly one citation in fifteen.
The queries where this matters most
The study found the effect was not uniform. It depended on what the person was asking.
For transactional questions, where someone already knows who they want and is looking for specifics, brand-owned content rose considerably. That makes sense: if you want a firm’s office address or its contact form, the firm’s own site is the correct source and the machine treats it that way.
For consideration questions, the pattern went the other way and got more extreme. Consideration questions are the ones that begin “best” or “who should I” or “which company for.” On those, ChatGPT drew almost entirely on earned sources, with minimal brand-owned content and virtually no social.
Consideration questions are what a person with a legal problem asks. Best malpractice lawyer in Cleveland. Who handles Camp Lejeune claims? Which firm should I call about a truck accident? These are the queries that decide who gets contacted, and they are the queries where a firm’s own website carries the least weight.
The limits of that study
While compelling, the data also should not be considered gospel. Here is what the Toronto researchers themselves disclose.
The data is a single snapshot from August 2025, in a field that moves fast. Their three-way classification is proprietary and, in their own word, subjective, since the line between an independent publication and a company blog is sometimes genuinely unclear. They caution that the absolute percentages should be read as illustrative of strong relative trends rather than as fixed facts, and that comparisons between engines are more reliable than the individual numbers. The work received support from a company that sells AI-visibility services.
None of that undoes the finding. The gap between 93.5% and 6.5% is far too wide to be an artifact of classification choices. The study also has a limitation for legal purposes in that it tested consumer product categories, not law firms.
A second method, with similar results
Muck Rack, which makes software for public relations professionals, analyzed more than 25 million links cited by ChatGPT, Claude, and Gemini across seventeen industries. Its finding: 84% of citations came from earned media. Journalism alone accounted for roughly a quarter. Paid and advertorial content accounted for 0.3%.
Muck Rack sells to PR firms, and this is a finding that helps them sell. But it is a completely different dataset, gathered by a different method over a longer period, and it landed within ten points of the academic result. Two methods converging is meaningfully stronger evidence than either one alone.
The full analysis is in our new report.
RebuttalPR is a litigation communications firm built for the plaintiffs’ bar. Through earned media, thought leadership, and the stories your cases produce, we build the authority and reputation that clients look for and that AI relies on. Our team are veterans of AAJ, state trial lawyer associations, and Public Justice. We do this work because we believe in the plaintiffs’ bar and the clients it serves. If something here raises a question about your own firm, reach us at the form below.
