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> I think it’s ultimately about whether training on copyrighted content is legal or not.

It is.

The bulk of the complaint is a narrative; it's meant to be a persuasive story that seeks to put OpenAI in a bad light. You don't really get to the specific causes of action until page 60 (paragraphs 158-180). A sample of the specific allegations that comprise the elements of each cause of action are:

160. By building training datasets containing millions of copies of Times Works, including by scraping copyrighted Times Works from The Times’s websites and reproducing such works from third-party datasets, the OpenAI Defendants have directly infringed The Times’s exclusive rights in its copyrighted works.

161. By storing, processing, and reproducing the training datasets containing millions of copies of Times Works to train the GPT models on Microsoft’s supercomputing platform, Microsoft and the OpenAI Defendants have jointly directly infringed The Times’s exclusive rights in its copyrighted works.

162. On information and belief, by storing, processing, and reproducing the GPT models trained on Times Works, which GPT models themselves have memorized, on Microsoft’s supercomputing platform, Microsoft and the OpenAI Defendants have jointly directly infringed The Times’s exclusive rights in its copyrighted works.

163. By disseminating generative output containing copies and derivatives of Times Works through the ChatGPT offerings, the OpenAI Defendants have directly infringed The Times’s exclusive rights in its copyrighted works.



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