The law firm Cooley worked with OpenAI to develop an AI tool that, its creators say, will help pre-IPO companies draft IPO registration statements faster and better.
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2026 and 2027 are shaping up to be record years for initial public offerings (IPOs). The SpaceX IPO raised $85.7 billion, and the eagerly anticipated IPOs of OpenAI (maker of ChatGPT) and Anthropic (maker of Claude) are expected to raise at least $60 billion and $100 million respectively.
The IPO process begins with the Form S-1 registration statement that an issuer (i.e. the company) files with the Securities and Exchange Commission (SEC) after extensive preparation by the law firm hired to draft it. The S-1 is the disclosure document that tells us all about the company. First filed confidentially with the SEC, the S-1 receives comments from the SEC staff, undergoes revision by the issuer, and is then filed publicly.
Investors and analysts are eager to get the S-1 and all that it tells about the company. The demand for S-1 disclosures is shown by a major news story last week from a Reuters journalist who revealed information from a leaked version of the still private Anthropic S-1.
A big development in the IPO-preparation world is an AI tool that the law firm Cooley has built in collaboration with OpenAI. Called GO Public, Cooley’s new AI agent will help pre-IPO companies draft the S-1 significantly faster.
Cooley is the top-ranked law firm for US issuer-side IPOs since 2016, according to Deal Point Data. Coincidentally, Cooley is also the legal counsel, along with Wachtell, Lipton, Rosen & Katz, in preparing the Form S-1 of OpenAI itself. It is not far-fetched to wonder whether that S-1 (filed June 8, 2026) is the first IPO-related SEC filing to be drafted at least in part by an AI tool developed specifically to prepare SEC filings. As I explain below, I speculate that it probably was, making OpenAI’s S-1 a historic document.
What GO Public Does
September marked four decades since I left life as a corporate and securities lawyer at a Boston law firm to devote my professional career to making complex legal and tax concepts understandable to people who do not enjoy reading the Internal Revenue Code or US securities laws. I do remain interested and connected both in the law-firm world I left behind and in the preparation of SEC filings, so GO Public intrigued me.
GO Public is an AI-enabled service built with ChatGPT Enterprise, compared to lawyers merely using general-purpose ChatGPT (or Claude) internally for preparing parts of an SEC filing. For technical reasons, Cooley was unable to provide me with a demo. However, I assume Cooley’s highly experienced SEC lawyers find that it produces a workable first draft of major S-1 sections. It’s likely that the AI tool uses as sources company documents, financial statements, and structured questionnaires.
This generative AI tool compresses the S-1 drafting period, which can take months for a complex company. It does not eliminate the lawyers’ roles or responsibilities, nor does it reduce anyone’s legal liability for an inaccurate disclosure filing. Teams of attorneys still review the output, make legal judgments, and perform due diligence.
The websites of both Cooley and Open AI provide some information about GO Public. The video embedded into Cooley’s GO Public page is worth watching. It much more resembles a technology company’s product-launch promo, or perhaps a trailer for yet another legal-themed TV show, than traditional law-firm marketing.
While I tried a few times via different routes to get the SEC to comment on GO Public and on the use of AI tools to prepare SEC filings, the agency did not respond. Neither did other major law firms actively involved with IPOs. Among them is Wilson Sonsini, which has a product called WS-1 designed to automate the S-1 preparation process. While I suspect that Wilson Sonsini’s tool will eventually include AI features, the firm (legal counsel to Anthropic for its IPO) did not reply to my emails.
Insights On GO Public From One Of Its Masterminds
As luck would have it, just as I received Cooley’s announcement email about GO Public, one of the firm’s top capital-markets lawyers, Richard Segal, was preparing to present on the IPO process at a myStockOptions.com online event I was moderating, the IPO Readiness Virtual Summit For Financial Advisors. When I glanced at the Cooley video on GOPublic he appeared in it, extolling its features and benefits in brief snippets along with other casually dressed lawyers at his firm.
I found revealing some of his comments in the video. Segal notes that the tool’s S-1 output includes “risk factors that are super-tailored to a company’s business and MD&A [Management’s Discussion and Analysis of Financial Condition and Results of Operations] that automatically draw from their financial statements.”
He goes on to proclaim that with GO Public, the company’s management can avoid spending valuable time hunting down the information needed and walking lawyers through it. “We can have AI do that,” he says, “and then we can have a really thoughtful conversation around the most sensitive issues.”
A few days after the IPO online event I moderated in which he spoke, I reached out to Segal for more details on GO Public. He answered my questions promptly, including my followups.
Initially I assumed Cooley’s development of GO Public was part of a trend at some major law firms to create proprietary AI tools around their own expertise that they sell (whether the product or the actual business) to companies and other law firms. This is not the case with Cooley’s tool.
“We are not selling GO Public,” Segal asserted. “It is part of our value proposition to clients who engage us as counsel for their IPOs.” That is similar to the approach Cooley has taken with Vanilla, its proprietary platform for private-investment-fund formation (e.g. venture capital and PE firms), investor subscriptions, and fund-management workflows. Cooley says on its website that Vanilla has handled “more than $100 billion in fund formations.” However, given the $550 million at a $15.5 billion valuation that legal AI company Harvey recently raised in September, I do wonder whether Cooley will eventually rethink its vision for GO Public.
SEC filings require many machine-readable metatags that identify specific sections and information for easy data extraction and analysis. I questioned whether the S-1 created in parts with the Cooley AI agent, even after its lawyers closely review the output, will leave any type of AI watermark that signals what text is based on AI-generated content. This is not a current SEC requirement, and the SEC did not respond to my question about whether the agency is considering it.
Segal explained that Cooley’s tool “does not identify what GO Public helped draft.” He repeated one of the firm’s themes in its framing of GO Public: “Nothing is truly ‘drafted by GO Public.’ Everything is drafted by lawyers with GO Public’s help.”
He also confirmed that his firm is developing similar types of AI tools for other frequent SEC filings and disclosures. These would include Form 10-Q, Form 10-K, and the annual proxy statement, all of which are required for every public company—not just IPO companies.
Recently, The New York Times published an article with the title As A.I. Makes Law Firms More Efficient, Clients Ask: ‘Where’s My Discount?’ This led me to ask whether any of Cooley’s clients have seriously, or even jokingly, said they expect a lower fee for work done by AI rather than human lawyers. He replied that, on the contrary, clients’ reactions have “been very positive,” with most interest centered on what the tool means for the client experience and making the IPO process more efficient.
I remain curious about how Cooley will charge for its innovation. A report from PwC’s Capital Markets Advisory team estimates that legal fees for an IPO range from $627,356 to $6,300,000. Actual fees will vary depending on the complexity, size, and IPO-readiness of the company.
Was Cooley’s AI Tool Used To Draft OpenAI’s S-1?
One question that Segal did not answer, even in a followup nudge, is whether a version of GO Public was used to prepare parts of the Form S-1 that OpenAI filed with the SEC. After all, OpenAI is an IPO client of Cooley, and it worked with Cooley on the development of the GO Public tool for IPO preparation.
His reticence did not surprise me. While the Cooley attorneys involved with creating GO Public speak with the enthusiasm of company founders in their flashy launch video, they remain lawyers concerned about unwanted SEC attention for gun-jumping that could precondition the market during the IPO process.
That didn’t stop me from exploring this mystery, given the timeline of OpenAI’s IPO, the announcement date of GO Public, and the collaboration between OpenAI and Cooley to create the AI tool. I could not dismiss the circumstantial evidence.
So I decided to ask ChatGPT directly for its thinking, uninhibited by its legal team. My paid Plus account must give me access in some way to its key engineers and executives!
Its answer to my prompt made my speculation at least tenable: “It therefore seems quite plausible that some predecessor, prototype, or beta version of GO Public was used during OpenAI’s IPO-preparation process.”
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