Tag: files

  • Are LLMs.txt Files Being Implemented Across the Web?

    Are LLMs.txt Files Being Implemented Across the Web?

    For the past year, our team at Archer has fully embraced the shift towards AI in enrollment marketing, especially in SEO. We have reshaped the way we think about the tools, experiences, and content we can deliver across the student journey. This radical shift in approach now has us pushing for more automation and innovation. 

    As a team, we decided to leave no stone unturned until we could reverse-engineer the output and influence it at will. Under that lens, we examined an emerging web standard for AI, the LLMs.txt file

    Are LLMs.txt files being implemented across the web? The short and simple answer is no. As of today, Anthropic is the only major player in the LLM space that supports this standard. But the file is getting crawled. As of this blog post, our log file shows that our LLMs.txt files have been pinged over 8,000 times

    The table below shows the total number of pings for eight sites that we tested this file with. 

    AGENT TOTAL %
    8LEGS 5 0.06%
    AhrefsBot 162 1.83%
    AhrefsSiteAudit 8 0.09%
    Applebot 3 0.03%
    AwarioBot 6 0.07%
    Barkrowler 20 0.23%
    bingbot 41 0.46%
    CCBot 5 0.06%
    Chrome/Safari 101 1.14%
    DataForSeoBot 10 0.11%
    Dataprovider.com 8 0.09%
    Edge 1 0.01%
    Facebook 1 0.01%
    facebookexternalhit 9 0.10%
    Firefox 14 0.16%
    Google-Apps-Script 3 0.03%
    Googlebot 55 0.62%
    GPTBot 2 0.02%
    meta-externalagent 6 0.07%
    Mobile Safari 4 0.05%
    Mozilla 3 0.03%
    Mozilla/5.0 26 0.29%
    OAI-SearchBot 8,330 94.35%
    Opera 1 0.01%
    PTST 9 0.10%
    Safari 1 0.01%
    Scrapy 1 0.01%
    search.marginalia.nu 1 0.01%
    SEOkicks 1 0.01%
    SemrushBot 12 0.14%
    SiteAuditBot 1 0.01%
    Slurp 1 0.01%
    Yahoo Slurp 1 0.01%
    YandexBot 8 0.09%
    TOTAL 8,829

    What is LLMs.txt and Why Does It Matter?

    If you’re tuned into the GEO/SEO debate, there seems to be a great shift in how LLMs differ from traditional search engines. An LLMs text file is most comparable to a robots.txt file, as it lives in the root directory of a site and provides instructions for crawling. The LLMs.txt file enables the conversion of your site’s information architecture into Markdown language, resulting in a simplified and clean view of your site’s structure. 

    This simple, clean view offers LLM crawlers an unmitigated path to your content, and that matters because LLMs cannot render JavaScript. This means that LLM scrapers are inferring context around a document from raw HTML. As Jono Alderson noted back in May 2025, this has a profound impact on how LLMs ingest your content. 

    Websites built using client-side rendering have a chance of displaying no content at all, which reduces the likelihood of your content being cited. Simply put, if LLMs can’t parse your content, then you won’t be able to stay competitive. 

    How Crawlers Are Interacting with Archer’s LLMs.txt Files

    When looking at the crawl numbers, OpenAI is dominating the crawl, with over 94% of our pings coming from OpenAI’s search bot. When examining the log file, we can see that the search bot pings our servers several times per hour, sometimes even within seconds of each other. 

    I had Gemini 2.5 analyze the log file for patterns, and here’s what it identified:

    This pattern is consistently observable throughout the logs. For example:

    • On June 26, 2025, the bot requested a URL from genericsite.com at 14:05:55 UTC and then again just three seconds later at 14:05:58 UTC.  
    • On July 10, 2025, genericsite2.com was subjected to a sustained burst of requests, with hits logged at 15:21:46, 15:23:03, 15:29:09, and 15:32:16 UTC.  
    • On July 6, 2025, two requests were made to the same domain just one second apart, at 02:49:15 and 02:49:16 UTC.

    When looking at the Ahrefs AI citations sections, we’ve only just begun to see an uptick in performance for citations across AI. The screenshot below shows what we’d expect from such low-traffic sites. A few weeks ago, when this reporting feature launched, these numbers were closer to zero.

    What’s also interesting  to note is that GPT bot pinged our LLMs.txt file for two smallers sites, which saw less pings from OpenAI’s search bot. GPT bot is exclusively used to train the model, so this indicates that OpenAI found our file valuable. 

    In full opaqueness, I’ve anonymized our sites to avoid malicious intent, but these sites are niche-specific. The sites focus on industry-specific degrees and mainly features informational content around career outcomes, licensure, variations of degrees, and helpful information for prospective students looking to enroll. There’s a lot of great information to train on and surface in outputs. 

    How Did We Get AI Bots to Crawl our LLMs.txt File?

    I saw your questions, asking us how we coaxed LLM bots to crawl our file. Many of you wanted to know if we added a link to our file; of course, we did! We treated this file like any other standard for SEO. If this were an XML sitemap, we’d submit it to Google Search Console and link to it on our robots.txt file.  So why wouldn’t we treat this standard the same way?

    I’m a big baseball fan, and our methodology for implementing the file is inspired by a line from one of my favorite baseball movies, Field of Dreams.

    “If you link to it, they will come.”

    Thanks to the brilliance of our team, we decided to approach this differently. Rather than listing a link to the file in robots.txt, which is common practice for an XML sitemap, we decided to inject a link to the file in the

    section of our sites. 

    We implemented this using the “alternate” link relationship type, which suggests an alternative version of a document. We expected to get crawls from all sorts of bots, but we didn’t expect to get so many in such a short period. 

    Have We Checked the IP Addresses of AI Bots?

    When I first announced this on Twitter, many of the initial comments inquired about IP abuse and malicious intent. Given the frequency of server pings, we were concerned about the potential for spoofers looking for site vulnerabilities.  We checked the IP address 135.234.64.13, which is identified within OpenAI’s documentation.

    Should You Implement LLMs.txt on Your Site?

    When looking at the evolving landscape, I’d say yes. Google has a 20-year head start, which enables it to parse unstructured data with ease. That’s a significant investment in infrastructure, which means competitors must raise substantial capital to catch up. 

    With that said, if you have a deadline-driven product, such as a master’s degree or a relatively new offering with limited documentation, and your site is not optimized for AI, your users may encounter hallucinations. I hypothesize that the LLMs.txt file serves as a safeguard, providing pertinent information to the LLMs and can help reduce errors by serving fresh content. 

    For example, a prospective student searches for a Fall application deadline, but LLM models have been trained on an earlier version of our site. LLMs need to do a live search or RAG to satisfy user intent. Another example might be sweeping changes to the curriculum for a new semester. How can we maintain accuracy for our students? 

    The Future of LLMs.txt

    I am not a crystal ball gazer, nor do I possess the power of prescience. At this moment, all we can do is test and monitor the file. Our team will continue to monitor bot behavior and report on our findings. 

    With each passing day, we’re seeing shifts in user behavior, improved models, and wide-scale change. No one knows what the future holds for agentic search, but I do know that the industry needs to evolve with the tech stack. 

    At Archer, our team would learn firsthand. It’s the only way we can future-proof our university partner’s success. In higher education, we face various challenges, including declining enrollments, which is an industry-wide issue.

    Final Thoughts on the LLMs.txt File

    While the LLMs text file is not yet a widely adopted standard across the web, the recent flurry of bot activity suggests there is value. Given the limitations of current LLM crawlers, this file might be your best bet in safeguarding against pitfalls that will have you excluded from these new systems. 

    As the industry evolves, it’s our duty as stewards of the web to test, try, break, and fix things. I encourage marketers, SEOs, and web engineers to think differently and lean into curiosity. It is through that lens that we can help our partners be found wherever their students are. 
    If you’d like to talk more about AI-powered SEO and how Archer is helping universities show up where students are searching, the Archer team is ready to help.

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  • DOL Files Appeal in Overtime Legal Challenge

    DOL Files Appeal in Overtime Legal Challenge

    by CUPA-HR | March 12, 2025

    On February 28, the Department of Labor (DOL) filed an appeal in Flint Avenue, LLC v. U.S. Department of Labor, which previously led a district court to strike down the agency’s overtime final rule set forth under the Biden administration. The action is the second pending appeal from DOL with respect to cases involving the Biden administration’s overtime rule and may be acting as a placeholder to provide time for the Trump administration to determine how they want to move forward with the Biden administration’s overtime rule.

    Background

    As a reminder, the Biden administration’s final rule implemented a phase-in approach to increasing the minimum salary threshold under the Fair Labor Standards Act (FLSA) overtime regulations. Specifically, the rule increased the minimum salary threshold, effective July 1, 2024, from the previous level of $684 per week ($35,568 per year) to a new level at $844 per week ($43,888 per year). This first increase used the same methodology set by the first Trump administration’s 2019 overtime rule to determine the new salary threshold level. The rule also aimed to increase the threshold a second time effective January 1, 2025; however, the Biden overtime rule was struck down in federal court before the second increase could take effect. This increase would have changed the minimum salary threshold again to $1,128 per week ($58,656 per year). Finally, the rule adopted automatic updates to the minimum salary threshold that would occur every three years.

    Shortly after the Biden overtime rule was published, lawsuits were filed challenging the final rule. These lawsuits resulted in two district court orders to vacate the final rule. On November 15, 2024, a federal judge in the Eastern District Court of Texas ruled to vacate the Biden administration’s FLSA overtime final rule in State of Texas v. U.S. Department of Labor. Similarly, on December 30, 2024, another federal judge in the Northern District Court of Texas ruled to vacate the Biden administration’s overtime rule in Flint Avenue, LLC. Both rulings vacated all components of the rule, meaning both the July and January salary thresholds set under the final rule were no longer in effect and automatic updates to the minimum salary threshold would not take place.

    DOL’s Appeals

    Soon after the federal judge ruled in the State of Texas case, the Biden administration’s DOL filed an appeal. The appeal was filed in the 5th U.S. Circuit Court of Appeals, where it remained through the presidential transition. On February 24, the Department of Labor under the Trump administration requested an extension to file its opening brief in the State of Texas appeal. The 5th Circuit Court agreed to the extension, allowing for opening briefs to be filed by May 6, 2025.

    Soon after, on February 28, DOL filed its second appeal to the 5th Circuit Court in the Flint Avenue case. Both actions may be intended to give time to newly confirmed Labor Secretary Lori Chavez-DeRemer to settle into her new role and determine how the Trump administration will move forward with litigation and the Biden administration’s rulemaking.

    CUPA-HR will continue to keep members apprised of legal updates regarding the overtime regulations.



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  • DOL files fresh appeal of a Texas decision vacating its new overtime rule

    DOL files fresh appeal of a Texas decision vacating its new overtime rule

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    Dive Brief:

    • The U.S. Department of Labor has appealed a Texas federal judge’s 2024 decision blocking its Biden-era final rule which sought to expand overtime pay protections under the Fair Labor Standards Act, according to a Feb. 28 court filing.
    • Last December, Judge Sam Cummings of the U.S. District Court for the Northern District of Texas ruled against DOL in Flint Avenue, LLC v. U.S. Department of Labor, vacating and setting aside the final rule. Cummings’ decision came just over one month after another Texas judge similarly vacated and set aside the rule in a separate lawsuit filed by the state of Texas and parties including the Plano Chamber of Commerce.
    • The appeal takes Flint Avenue to the 5th U.S. Circuit Court of Appeals, the same court in which DOL filed an appeal of the decision in the State of Texas case last year. DOL’s public affairs staff did not immediately respond to a request for comment. The U.S. Department of Justice, which represents the DOL, did not respond to a request for comment submitted via its online form.

    Dive Insight:

    The Feb. 28 notice of appeal may come as a surprise to employers who expected the Trump administration to abandon the final rule; attorneys who previously spoke to HR Dive said that the rule was effectively “dead” despite DOL’s State of Texas appeal because of the Trump administration’s conservative policy stance on overtime.

    In fact, the new administration had already filed motions in the 5th Circuit pertinent to overtime rule litigation. On Jan. 22, two days after President Donald Trump’s inauguration, DOJ attorneys sent a letter to the 5th Circuit requesting a 30-day extension on the deadline set by the court to file an opening brief in the State of Texas appeal. The court granted the request and the agency’s filing deadline is currently set to March 7.

    The April 2024 final rule proposed a two-step process that would have eventually raised the minimum annual salary threshold for overtime pay eligibility under the FLSA from $35,568 to $58,656 by Jan. 1, 2025. The rule would then have implemented a mechanism for automatically adjusting the threshold every three years using current wage data beginning in July 2027.

    But a series of Texas court decisions froze the rule. The judge in State of Texas held that the rule exceeded DOL’s authority and was unlawful. Likewise, Cummings said in his decision that he found the State of Texas judge’s reasoning “persuasive,” and he adopted the same reasoning in ruling for the plaintiffs.

    There is some intrigue in how the 5th Circuit might rule on the two appealed judgments given that the court signed off on DOL’s overall use of a salary basis test for determining overtime pay eligibility in last year’s Mayfield v. U.S. Department of Labor. The Mayfield plaintiffs alleged that the salary basis test had no basis in the FLSA’s text, but the 5th Circuit disagreed. The court did hold, however, that DOL “cannot enact rules that replace or swallow the meaning” of the FLSA’s text, adding that particular salary threshold may raise legal issues because of their size.

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  • NLRB Region Files Complaint Against the NCAA, Pac-12 and the University of Southern California – CUPA-HR

    NLRB Region Files Complaint Against the NCAA, Pac-12 and the University of Southern California – CUPA-HR

    by CUPA-HR | December 21, 2022

    On December 15, the National Labor Relations Board (NLRB)’s Region 31 announced it will pursue a complaint against the National Collegiate Athletic Association (NCAA), the Pac-12 Conference and the University of Southern California (USC) for violating the National Labor Relations Act (NLRA) by misclassifying student-athletes as non-employees, unless the matter is settled. On February 8, the National College Players Association filed an unfair labor practice (ULP) charge with the region alleging that USC; the University of California, Los Angeles; the Pac-12 Conference; and the NCAA are “joint employers” who violated the NLRA by “repeatedly misclassifying employees as ‘student-athlete’ non-employees.”

    Region 31 is part of the NLRB’s Office of General Counsel, which is responsible for receiving charges from employees, unions or employers that allege violations of the NLRA. The region decides whether to issue a complaint on charges it receives. If the region does not issue a complaint, the matter is generally closed. If the region decides to file a complaint, however, the case is litigated before an administrative law judge.

    Region 31’s complaint is the latest development regarding the employment status of student-athletes. The National College Players Association’s February 8 charge followed NLRB General Counsel Jennifer Abruzzo’s memorandum issued last September in which she argues that student-athletes are employees under the NLRA and are therefore afforded all statutory protections as prescribed under the law.

    The region’s decision in response to the February ULP charge means the NCAA, Pac-12 Conference and USC can either settle or litigate the case. A final ruling could take years to come to fruition, however, as both parties in the case could appeal the decisions made by the administrative law judge to the five-member NLRB. The NLRB’s decision can be appealed to federal appellate courts  and from there all the way up to the Supreme Court.

    The news of the region’s complaint follows the announcement earlier in the day that Massachusetts Governor Charlie Baker would be the NCAA’s next president in March after his last term in office expires in January. Baker, a Republican, is known for his work to build bipartisan consensus on policy in Massachusetts, which the NCAA may recognize as a strength as they continue to engage Congress on other issues related to student-athlete compensation. It is unclear what, if any, impact this will have on the ULP charges.

    CUPA-HR will continue to keep members apprised of this case and others involving student-athlete employment classification that may emerge in the future.



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  • CUPA-HR Files Comment Extension Request to USDA Regarding New Blacklisting Regulation for Federal Contractors – CUPA-HR

    CUPA-HR Files Comment Extension Request to USDA Regarding New Blacklisting Regulation for Federal Contractors – CUPA-HR

    by CUPA-HR | March 21, 2022

    On February 17, the U.S. Department of Agriculture (USDA) issued a Notice of Proposed Rulemaking (NPRM) outlining plans to impose new HR-related conditions on USDA contracts. If finalized, the rule would require federal contractors on projects procured by the USDA to certify their compliance with dozens of federal and state labor laws and executive orders. The proposal mirrors similar “blacklisting” regulations pursued by the USDA during the Obama administration.

    The USDA provided only 32 days for stakeholders to submit comments on the proposal. CUPA-HR, along with several other higher education associations, filed an extension request with the department asking for an additional 90 days to “evaluate the NPRM’s impact on [members’] research missions and collect the information needed in order to provide thoughtful and accurate input to the USDA.” CUPA-HR plans to file comments on the proposal as well.

    The new proposed rulemaking amends the Agriculture Acquisition Regulation (AGAR) to require federal contractors on USDA supply and service projects that exceed the simplified acquisition threshold to certify that they and their subcontractors and suppliers are “in compliance with” 15 federal labor laws, their state equivalents and executive orders. This includes, but is not limited to:

    • Fair Labor Standards Act;
    • Occupational Safety and Health Act;
    • National Labor Relations Act;
    • Service Contract Act;
    • Davis-Bacon Act;
    • Title VII of the Civil Rights Act;
    • Americans with Disabilities Act;
    • Age Discrimination in Employment Act; and
    • Family and Medical Leave Act.

    Additionally, federal contractors submitting offers for a project would be required to disclose to the USDA previous violations and certify they and their subcontractors “are in compliance with” any required corrective actions for those violations. They would also be required to alert USDA to any future adjudications of non-compliance.

    In 2011, the USDA tried to implement a similar policy via a Direct Final Rule and NPRM, but was forced to withdraw both due to stakeholder pushback. CUPA-HR filed comments with the Society for Human Resource Management calling the rules arbitrary and capricious. Our comments also criticized the rules for not adequately clarifying how contractors were expected to comply with the changes and for imposing severe penalties. Additionally, CUPA-HR joined comments filed by the American Council on Education and several other higher education associations that argued the USDA’s rules “impose[d] an unmanageable compliance burden and uncertain compliance risk for colleges and universities that conduct agricultural research under contracts with the [USDA].”

    Additionally, the Obama administration issued an executive order in July 2014 implementing a similar government-wide policy. The Federal Acquisition Regulation (FAR) Council and the Department of Labor issued regulations and guidance, respectively, implementing the order, but they were blocked by a federal judge in October 2016 for violating the First Amendment and due process rights. Congress also passed a Congressional Review Act challenge to the executive order in 2017, permanently withdrawing the executive order and barring the FAR Council from issuing any substantially similar regulations.

    Unlike past proposals, this time the USDA has stated that the certifications will be subject to the False Claims Act (FCA), which provides for substantially increased liability. The FCA provides for treble damages and penalties and allows for private citizens to file suits on behalf of the government (called “qui tam” suits). Qui tam litigants receive a portion of the government’s recovery. According to the Department of Justice (DOJ), the awards to qui tam litigants in FCA suits topped $238 million in 2021. The same DOJ statistics show qui tam suits were the majority of FCA claims, with the government filing 203 new suits under FCA in 2021 compared to 598 qui tam suits in the same year.

    CUPA-HR will continue to monitor this issue closely.



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  • National College Players Association Files Charges Seeking Employee Status for Student-Athletes – CUPA-HR

    National College Players Association Files Charges Seeking Employee Status for Student-Athletes – CUPA-HR

    by CUPA-HR | February 17, 2022

    On February 8, the National College Players Association (NCPA), an advocacy association for college athletes, filed unfair labor practice charges with the National Labor Relations Board (NLRB) against the University of Southern California, the University of California, Los Angeles (UCLA), the Pac-12 Conference and the National Collegiate Athletic Association (NCAA).

    The charges allege that the employers have violated the National Labor Relations Act (NLRA) by “repeatedly misclassifying employees as ‘student-athlete’ nonemployees” and “by maintaining unlawful rules and policies in its handbook, including restricting communications with third parties.” The charges mark the launch of the NCPA’s #JforJustice campaign and aim “to affirm college athlete employee status for every [Football Bowl Subdivision (FBS)] football player and Division I basketball player at every public and private university in the nation,” per an NCPA statement.

    This is the latest development regarding issues surrounding employment status of student-athletes since NLRB General Counsel Abruzzo issued a memorandum last September stating her position that student-athletes are employees under the NLRA and are therefore afforded all statutory protections as prescribed under the law. In that memo, Abruzzo stated that it was her intent to “educate the public, especially Players at Academic Institutions, colleges and universities, athletic conferences and the NCAA” about her position in future appropriate cases.

    The NCPA charges potentially provide Abruzzo with a case she can present to the NLRB to consider granting collective bargaining rights to college athletes. In 2015, the last time the NLRB considered the issue, it declined to assert jurisdiction over Northwestern football players, as doing so “would not promote labor stability [because the] board does not have jurisdiction over state-run colleges and universities” that make up the majority of the FBS. The NCPA charge seeks to overcome this jurisdictional obstacle by including the privately-held Pac-12 and NCAA as joint employers of UCLA’s athletes — a theory of liability Abruzzo said she would consider applying in appropriate circumstances.

    Now that the charges have been filed, an NLRB regional director will review the case and determine whether formal action should be taken and presented to an administrative law judge, which would preside over a trial and issue a decision that could ultimately be taken up by the five-member board.

    CUPA-HR will be paying close attention to this case and provide members updates as it progresses.



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