OpenAI: 11 qualifying events in 90 days, ten of them in September

OpenAI logged 11 qualifying events in the US in the last 90 days, from 7 July to 5 October 2026, across six event classes. September carried ten of them. On 15 September OpenAI acquired Glass Imaging for $300 million (Yahoo Finance), and on 9 September it spent $22.5 million on academic research (Marcus on AI).

The capital story turned within a fortnight. On 15 September OpenAI was considering a round at a $1.2 trillion valuation ahead of a planned IPO (Investing.com); on 16 September it took the 2026 IPO off the table (Forkast News). By 30 September it was pursuing $30B at a $1.4 trillion valuation (CoinDesk Policy). The listing is off.

The legal file grew alongside. On 30 September OpenAI signed a voluntary accord with the US President covering external audits and board-level AI governance committees (Verdict Tech). Dario Amodei, CEO of Anthropic, said of the accord: “The technology has very real risks. And, you know, the mechanism, how we address those risks is still under discussion.” On 10 September OpenAI was reported as the target of a Florida criminal investigation opened in April 2026 (Forkast News). On 19 September a judge blocked its access to a confidential Apple settlement (Crypto Briefing), and on 2 October it faced copyright and product liability claims (Axios Pro Deals).

On 10 September OpenAI extended ChatGPT to 23 million US public-sector employees (Crypto Briefing), and on 25 September it terminated contractor positions after finding contractors using AI tools on human-review work (Computerworld).

For US law firms, Corporate and M&A work comes first: the Glass Imaging deal and a $30B private raise create acquisition and financing work, and the accord's board committees add governance mandates. Re-engagement follows, as the 30 September accord gives partners a reason to return to AI clients' boards on audit readiness.

Insolvency and employment work sits in the 25 September contractor terminations, which turn on the contractual terms the contractors broke. Commercial and property demand sits in the 10 September public-sector rollout, which runs on government procurement terms. It matters most to partners and business development teams advising AI developers.