Beginning December 21, 2020, with version 1.6 of CM/ECF, the functionality that inspects and validates PDFs being submitted has been updated to prevent malformed documents or documents containing code which may cause an external action from being filed. As part of this updated functionality, the user will be presented with a warning message when a PDF not meeting the inspection validation criterion is attempted to be filed.
The following covers the new validation functionality, steps you can take to ensure valid PDFs before filing, guidance on fillable PDFs, and known issues with problematic PDFs filed prior to CM/ECF v1.6.
Fillable PDFs should not be filed in CM/ECF, however, the system will not prevent these PDFs from being filed, if they pass the validation inspection criterion. A fillable PDF filed into the system will prevent certain PDF viewing functions from working properly. In addition, anyone downloading a fillable PDF from the system will still have access to the fillable functions of the PDF and it will appear they are able to make changes, even though the original is not changeable in the system.
What happens if I file a fillable PDF document?
If a fillable PDF with multiple attachments is filed and a user attempts to view the complete combined filing using the ‘View All/Download All’ option, the system will return the following message:
‘Unable to create combined PDF file.’
Users will be required to open each attachment separately.
What should I do before filing a fillable PDF document?
To prevent this situation, filers should “flatten” their fillable PDFs prior to filing. The simplest method is to “Print” the fillable PDF to a new PDF file name. Please note that using “save as” or “export to PDF” functionality will not remove the fillable functions. This could result in the PDF being rejected upon submission or result in the issue above, where users are not able to use the ‘View All/Download All’ functionality and will be required to open each attachment separately.
Enhanced PDF Validation and Malformed PDFs
With version 1.6 of CM/ECF, the functionality that inspects PDFs being submitted has been updated to prevent malformed documents or documents containing code. This enhanced PDF validation may cause an external action from being filed and as part of this updated functionality, the user will be presented with a warning message when a PDF not meeting the inspection criterion is attempted to be filed.
PDFs submitted WILL BE REJECTED for the following reasons:
- PDFs that do not comply with formatting standards;
- PDFs that are password protected;
- PDFs that contain scripts that launch an external application;
- PDFs with internal attachments;
- PDFs with audio and video content;
- PDFs created on Mac OS X using a fillable form in the Safari browser*
- PDFs created with MS Word on Mac OS X using the “Best for printing” option*
*See Mac OS X Specific Issues Below
However, please keep in mind that some attributes and functions within PDF documents are allowed and ACCEPTABLE in CM/ECF. These include:
- PDFs that contain hyperlinks to external web sites;
- PDFs meeting the PDF-A standard;
- PDFs with optical character recognition (OCR) metadata; PDFs containing scanned documents
For PDFs failing to meet the validation criterion, the following error message will be presented, and the submission halted:
ERROR: Document is malformed or contains code which may cause an external action (such as launching an application). This PDF document cannot be accepted.
Below are some of the common error messages a filer might encounter and how the isee with the PDF can be resolved.
I received an error message about my PDF being malformed. How do I fix the PDF?
The most common method to remedy this issue is to flatten the PDF, as outlined in the Fillable PDF section above.
When filing documents electronically, why do I get the message “ERROR: this document has security measures in effect"?
The system will not accept documents which have security measures turned on (for example, password protection in Adobe.) Remove the security features from the document and submit your document again.
What does this error message mean? "ERROR: Document contains code which may cause an external action (such as launching an application). This PDF document cannot be accepted."
It may also be that the PDF software or service you are using contains an advertisement. This is not acceptable in CM/ECF and must be removed before the document can be e-filed.
I use Mac OS X and Fillable Forms on Safari and received the error message, what can I do?
If you are working with a fillable form, try using a Chrome browser. Once ready, use the print to PDF functionality described in the Fillable PDF section above to flatten the document.
I use Mac OS X and MS Word to create PDFs and received the error message, what can I do?
If you use Microsoft Word to create your PDF file, select the option “Best for Electronic Distribution”.
Problematic PDFs filed prior to CM/ECF v1.6
I received an error message unable to create combined PDF file?
The error message is notifying the user that a malformed PDF or fillable PDF has been included within the filing you are trying to access. The ‘View All/Download All’ options cannot be used in this instance. The filing and attachments are still accessible by clicking on each filing separately.
Why is the blue electronic stamp missing from the top of documents that were e-filed?
Once the CM/ECF upgrade has been performed, when a user accesses any filings made prior to December 21, 2020 that have been identified as containing malformed or containing code that causes external action, the blue header that appears at the top of the page containing the filing date and document number will not be displayed.
Some PDF documents, especially those that have been scanned, might contain metadata which may cause this problem. Do not re-file the document unless so directed by the Court. For future filings, please flatten or sanitize your PDF document prior to filing.
The court will be reviewing all previously filed malformed documents and, as necessary, will be making notations on the docket sheet for those entries impacted. This process will take time, therefore, you may encounter issues mentioned above before any notations have been made. If you have any questions, please contact our help desk.