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Case Tracker: Artificial Intelligence, Copyrights and Class Actions

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What started as three separate cases—Alter v. OpenAI, Authors Guild v. OpenAI, and Basbanes v. OpenAI) has been consolidated into a single action against OpenAI and Microsoft. Plaintiffs alleged that OpenAI and Microsoft are liable for copyright infringement arising from the use of plaintiffs’ works to train defendants’ AI models.

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Basbanes is currently stayed pending a ruling on class certification in Alter v. OpenAI.

Case Background 

Authors Guild v. OpenAI Inc., No. 1:23-cv-08292

Alter v. OpenAI Inc., No. 1:23-cv-10211

Basbanes v. Microsoft Corporation, No. 1:24-cv-00084

Court: Southern District of New York

Judges: District Judge Sidney H. Stein and Magistrate Judge Ona T. Wang

Alter Plaintiffs – Jonathan Alter, The Authors Guild, David Baldacci, Kai Bird, Mary Bly, Taylor Branch, Rich Cohen, Michael Connelly, Sylvia Day, Jonathan Franzen, John Grisham, Elin Hilderbrand, Christina Baker Kline, Maya Shanbhag Lang, Victor LaValle, Eugene Linden, George R.R. Martin, Daniel Okrent, Jodi Picoult, Douglas Preston, Roxana Robinson, Julian Sancton, George Saunders, Stacy Schiff, Hampton Sides, James Shapiro, Jia Tolentino, Scott Turow, Simon Winchester, and Rachel Vail, on behalf of themselves and a putative class, represented by Susman Godfrey LLP (certain plaintiffs also represented by Lieff Cabraser Heimann &amp; Bernstein, LLP)&nbsp;

Basbanes Plaintiffs– Nicholas A. Basbanes and Nicholas Ngagoyeanes (professionally known as Nicholas Gage), individually and on behalf of all others similarly situated, represented by Grant Herrmann Schwartz &amp; Klinger LLP&nbsp;

Microsoft – Microsoft Corporation, represented by Orrick, Herrington &amp; Sutcliffe LLP and Faegre Drinker Biddle &amp; Reath LLP&nbsp;

OpenAI – OpenAI, Inc., OpenAI GP LLC, OpenAI, LLC, OpenAI OpCo LLC, OpenAI Global LLC, OAI Corporation, LLC, OpenAI Holdings, LLC, OpenAI Startup Fund I LP, OpenAI Startup Fund GP I LLC, OpenAI Startup Fund Management LLC, represented by Latham &amp; Watkins LLP, Morrison &amp; Foerster LLP, and Keker, Van Nest &amp; Peters LLP

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Status Updates 

Oct. 31, 2024 - Court set January 8 deadline for amending the pleadings

In addition to addressing various discovery disputes, this order set a January 8 deadline for the parties to amend the pleadings or add new parties.

Sept. 30, 2024 – Basbanes stayed

The plaintiffs stipulated and agreed to streamline the cases, so that the class allegations will be decided under the <a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-47-First-Consolidated-Class-Action-Complaint.pdf">consolidated complaint</a> filed by the Alter plaintiffs and Authors Guild plaintiffs and the class allegations from the Basbanes <a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-1-Basbanes-v-OpenAI.pdf">complaint</a> are dismissed. The parties agreed to stay Basbanes pending a court decision on class certification in the consolidated case.

Aug. 12, 2024 – OpenAI Defendants filed opposition to notice of dismissal 

OpenAI opposed Ms. Lang’s notice of dismissal [145 &amp; 146] because Lang is “uniquely situated among the named plaintiffs in” the case and is “uniquely capable of providing evidence directly relevant to OpenAI’s defense that, given the Authors Guild’s position with respect to its custodians, no other party will provide.” OpenAI clarified that it does not object to Ms. Lang’s decision to withdraw and had repeatedly offered to make accommodations for her personal circumstances, but OpenAI still insisted she comply with the basic discovery obligations that attached as soon as she chose to initiate and participate in the action.&nbsp;&nbsp;

July 30, 2024 – Maya Shanbhag Lang filed notice of voluntary dismissal 

Pursuant to F.R.C.P. Rules 41(a)(2) and 21, Maya Shanbhag Lang requested leave to withdraw as a plaintiff in the action for personal and family reasons. Ms. Lang cited circuit history for the proposition that a plaintiff may withdraw absent substantial prejudice to the defendant, and argued this withdrawal, of one plaintiff out of 30, would not prejudice defendants.&nbsp;&nbsp;

Ms. Lang was a former president of the Authors Guild, which Ms. Lang emphasized is a party to this case and produces relevant discovery outside of Lang’s presence. Thus, Ms. Lang argued that her withdrawal should not be conditioned upon her production of discovery responses: “Defendants have been informed that Ms. Lang’s resignation from the Authors Guild had nothing to do with this case or what is at issue in it, yet still attempt to hold unrelated discovery over Ms. Lang’s head as a condition of supporting a withdrawal that is justified legally and equitably regardless.”

Apr. 1, 2024 – SDNY denied Tremblay plaintiffs’ motions to intervene

The Tremblay plaintiffs had filed motions to intervene in each of the AI copyright actions pending before the Southern District of New York for the purpose of moving to dismiss, stay, or transfer these actions.&nbsp;

The court denied this action, finding the following:&nbsp;

The Tremblay plaintiffs had not met the requirements of Rule 24(a) insofar as they had not demonstrated a cognizable interest or that any such interest would be impaired. Specifically, the court found that the substantial differences between the actions lessened any risks of contradictory rulings.&nbsp;&nbsp;

Moreover, no class has been certified in the actions pending in California or New York; as such, the court held that the Tremblay plaintiffs had no legally cognizable interest in avoiding rulings that apply to entirely different plaintiffs in a different district. Even if a court did certify a class that involved the Tremblay plaintiffs, the court found that the Tremblay plaintiffs rights would be protected, not impaired, because classes are only certified after finding that the representative plaintiff would adequately protect the class’s interests.&nbsp;&nbsp;

Finally, the court found that the Tremblay plaintiffs did not show that the existing parties would fail to adequately represent their hypothetical interest. The court did not find the Tremblay plaintiffs’ argument sufficient that the existing parties do not adequately represent their interest because the Authors Guild, a plaintiff in the New York cases, publicly indicated an intention to license intellectual property rights to OpenAI. This is because the Authors Guild is only one of many plaintiffs. Additionally, the court stated that even for that single plaintiff, an interest in licensing intellectual property rights did not undermine Authors Guild’s interest in or ability to vigorously litigate the case and attempt to hold defendants accountable.&nbsp;

The court also denied permissive intervention because the same factors motivating the court’s denial of intervention as of right—the lack of cognizable interest, the lack of impairment of any interest, and the adequacy of representation—also motivated denial of permissive intervention. Specifically, courts have discretion under Rule 24(b) to permit a party to intervene that has a claim or defense that shares with the main action a common question of law or fact where such intervention will not unduly delay or prejudice the adjudication of the original parties’ rights.&nbsp;

Here, the Tremblay plaintiffs explicitly stated that they were intervening “for the limited purpose of filing this Motion to Dismiss, Stay, or Transfer.” The court found that a dismissal, stay, or transfer of the case would prejudice the original parties.&nbsp;

The court also noted that intervention and dismissal or transfer would disrupt the expedited timeline agreed to by the parties.&nbsp;

Given the above, the court denied the Tremblay plaintiffs’ motions to intervene by right and by permissive intervention.

Feb. 26, 2024 – Alter and Authors Guild plaintiffs filed response to Microsoft’s opposition to motion to intervene

Plaintiffs responded to [79] Microsoft’s opposition to <a href="https://www.bakerlaw.com/openai-chatgpt-litigation/" target="_blank" rel="noreferrer noopener">In re OpenAI ChatGPT Litigation</a> plaintiffs’ motions to intervene, agreeing with Microsoft that the court should deny the proposed intervenors’ motion. Plaintiffs stated that their actions have progressed quickly and efficiently, as pleadings are settled, discovery is underway, and summary judgment will be fully briefed by next year. Plaintiffs argued that the proposed intervenors seek to slow their progress “so they can exercise nationwide control over any case alleging copyright infringement against OpenAI.” The proposed intervenors are a different group of copyright owners with a separate action against OpenAI (and not Microsoft), involving different claims and issues, being tried in a separate district.

Feb. 26, 2024 – OpenAI filed response to Tremblay plaintiffs’ motion to intervene

OpenAI responded that it does not take a position on <a href="https://www.bakerlaw.com/openai-chatgpt-litigation/" target="_blank" rel="noreferrer noopener">OpenAI ChatGPT Litigation</a> plaintiffs’ motion to intervene.

Feb. 26, 2024 – Microsoft opposed to Tremblay plaintiffs’ motion to intervene

Microsoft conditionally opposed <a href="https://www.bakerlaw.com/openai-chatgpt-litigation/" target="_blank" rel="noreferrer noopener">In re OpenAI ChatGPT Litigation</a> plaintiffs’ motions to intervene because while Microsoft is a defendant in each of the New York actions, it is not a defendant in In re OpenAI ChatGPT Litigation in the Northern District of California.&nbsp;&nbsp;&nbsp;

Microsoft further stated that it is defending the cases with deliberate speed and pursuant to the Second Circuit’s instructions regarding the handling of copyright class actions as established in Authors Guild v. Google, and argued similarities between its fair use defense in this action to Authors Guild v. Google, suggesting that the Second Circuit will similarly find that the interests of justice and judicial efficiency here are best served by addressing fair use on summary judgment prior to reaching the issue of class certification. Microsoft characterized California plaintiffs’ motions to intervene as “jockeying for position among putative class counsel in two separate jurisdictions” and argued that the court should reject California plaintiffs’ motions for “at least three reasons: (1) the California plaintiffs lack standing to intervene; (2) even if they had standing the first-filed rule does not apply; and (3) in all events, justice and judicial efficiency compel denial.”&nbsp;

Feb. 16, 2024 – OpenAI answered first consolidated complaint

In its answer [75], OpenAI denied all allegations, arguing that training the model to learn “concepts and the building blocks of intelligence” qualifies as paradigmatic transformative fair use of copyrighted materials. In support, OpenAI argued that processing copyrighted works to extract information about the work like word frequencies, syntactic patterns, and thematic markers does not infringe copyright protections because it does not involve any communication of protected expression, nor does it replicate protected expression. OpenAI argued that the purpose of AI models is to create new material based on an understanding of language, reasoning, and the world, such that the models “learn, as [humans] all do, from what has come before.” Regarding plaintiffs’ three claims, OpenAI denied all allegations and cited to Arica Inst., Inc. v. Palmer, 970 F.2d 1067, 1077 (2d Cir. 1992) to argue that its generative AI training “passes with flying colors ‘the ultimate test of fair use’: ‘whether the copyright law’s goal of promoting the Progress of Science and useful Arts would be better served by allowing the use than by preventing it.’”&nbsp;&nbsp;

OpenAI asserted the following defenses: (1) fair use; (2) that the complained-of use was validly licensed by express or implied license; (3) doctrines of waiver, abandonment, and/or forfeiture; (4) doctrine of laches; (5) doctrine of estoppel; (6) OpenAI’s conduct was innocent, not willful; (7) statute of limitations; (8) plaintiffs’ failure to mitigate its alleged damages; (9) that some of the material covered in plaintiffs’ claimed copyright is in the public domain; (10) doctrine of merger; (11) idea/expression dichotomy; (12) that the material in which plaintiffs claim copyright constitutes “scenes a faire”; and (13) that the copyright of copyrightable expression is de minimis.&nbsp;

OpenAI refiled its answer on March 4, 2024 [67].&nbsp;

Feb. 16, 2024 – Microsoft answered first consolidated complaint

Microsoft filed its answer to plaintiffs’ consolidated complaint independently from OpenAI. Regarding plaintiffs’ three claims, Microsoft denied having trained the models at issue and that any works were infringed. Microsoft asserted the following defenses: (1) failure to state a claim, (2) fair use, (3) substantial non-infringing use, (4) works or elements of work not protected by copyright, (5) DMCA safe harbor provisions, (6) de minimis copying, (7) acts of third parties separate from Microsoft, (8) lack of injury as a result of the alleged conduct, (9) unavailability of injunctive relief, and (10) unconstitutional damages.

Feb. 12, 2024 – <a href="https://www.bakerlaw.com/openai-chatgpt-litigation/" target="_blank" rel="noreferrer noopener">OpenAI ChatGPT Litigation</a> plaintiffs filed motion to intervene as first-filed class action plaintiffs

Intervenors Tremblay, Silverman, Kadrey, and Chabon, among others, filed motion to intervene and asked the Southern District of New York to apply the first-to-file rule and dismiss, or in the alternative, stay or transfer Authors Guild and Alter cases, as well as <a href="https://www.bakerlaw.com/new-york-times-v-microsoft/" target="_blank" rel="noreferrer noopener">New York Times</a> and <a href="https://www.bakerlaw.com/basbanes-v-microsoft/" target="_blank" rel="noreferrer noopener">Basbanes</a>. Intervenors fear that OpenAI “is creating the likelihood—or certainty—of inconsistent rulings in overlapping class actions and the attendant waste of judicial resources.” Intervenors argued that the court should permit intervention as a matter of right, pursuant to FRCP § 24(a)(2). If not, they argued that the court should permit permissive intervention for the fact that the actions involve substantially similar defendants, the same putative nationwide class, the same AI technology, and substantially similar claims.&nbsp; Additionally, they argued that the first-to-file rule warrants dismissal of Authors Guild, Alter, New York Times, and Basbanes because intervenors’ actions are competing lawsuits.

Feb. 6, 2024 – Authors Guild and Alter plaintiffs filed a consolidated complaint

Both plaintiffs filed a consolidated complaint against Microsoft and OpenAI, alleging three causes of action –

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Feb. 5, 2024 – Authors Guild plaintiffs responded to request for consolidation

The&nbsp;Authors Guild&nbsp;plaintiffs responded [30] to the&nbsp;Basbanes&nbsp;plaintiffs’ motion to consolidate [23]. The&nbsp;Authors Guild&nbsp;plaintiffs did not oppose consolidation of the cases, and concurred with the&nbsp;Basbanes&nbsp;plaintiffs that appointment of the Author Plaintiffs’ counsel as co-lead counsel was appropriate at this time.

The&nbsp;Authors Guild&nbsp;plaintiffs did oppose, however, the creation of a steering committee that only included&nbsp;Basbanes&nbsp;counsel, noting there did not appear to be any reason nor benefit for the Author Plaintiffs.

Feb. 5, 2024 – Basbanes plaintiffs requested consolidation with Authors Guild and Alter cases

Plaintiffs requested [31] the court consolidate&nbsp;Basbanes&nbsp;with&nbsp;Authors Guild&nbsp;and&nbsp;Alter v. OpenAI&nbsp;(formerly&nbsp;Sancton v. OpenAI). Plaintiffs withdrew their request for their counsel to serve as interim co-lead counsel as moot.

Plaintiffs also requested, however, that the court set a briefing schedule to resolve the issue of whether a steering committee is necessary. Plaintiffs argued that the steering committee would allow plaintiffs’ counsel to ensure plaintiffs’ interests be represented. Plaintiffs’ counsel alleged that&nbsp;Authors Guild&nbsp;counsel proposed that: (1) plaintiffs’ counsel could only do work authorized by&nbsp;Authors Guild&nbsp;counsel, (2) any authorized work would only be “considered in any fee application,” (3) plaintiffs’ counsel could not seek fees for prior work, and (4) nothing in the agreement prevented plaintiffs’ counsel from staying abreast of litigation, which does not constitute work requested nor authorized.

Jan. 26, 2024 – Court endorsed both parties’ proposed schedule 

Both parties submitted a proposed schedule for fact discovery, expert discovery, and summary judgment briefing to the court, to which the court ordered. The next deadline listed is for substantial production of requested documents, due June 14, 2024.

Jan. 26, 2024 – OpenAI responded to plaintiffs’ class certification 

OpenAI submitted a letter in response to plaintiffs’ motion to appoint interim co-lead counsel for the fiction and nonfiction authors’ classes. OpenAI intends to oppose class certification and will reserve all arguments to challenge class certification for a future date, but in the current correspondence, OpenAI stated that it takes no position on plaintiffs’ motion to appoint interim co-lead counsel.&nbsp;&nbsp;

Jan. 24, 2024 – Court ordered Authors Guild and Alter plaintiffs to file a consolidated complaint

Plaintiffs in <a href="https://www.bakerlaw.com/authors-guild-v-openai/" target="_blank" rel="noreferrer noopener">Authors Guild v. OpenAI</a> and Alter v. OpenAI are joining their cases against OpenAI and Microsoft.&nbsp;&nbsp;

Jan. 23, 2024 – Basbanes plaintiffs requested consolidation with Authors Guild

The plaintiffs requested [23] that this case be consolidated with&nbsp;Authors Guild&nbsp;and appoint plaintiffs’ counsel from both cases as interim co-lead counsel. The plaintiffs also requested the court create a steering committee including the Basbane plaintiffs’ counsel.

Jan. 9, 2024 – Basbanes related to Authors Guild

The court related this case to&nbsp;Authors Guild v. OpenAI, assigning it to the same judge, Judge Stein.

Jan. 5, 2024 – Basbanes plaintiffs filed complaint

Named plaintiffs Nicholas A. Basbanes and Nicholas Ngagoyeanes (professionally known as Nicholas Gage) filed this complaint alleging various claims of copyright infringement based on the creation of LLMs . The complaint alleged three causes of action:

Dec. 19, 2023 – Alter plaintiffs filed first amended complaint

Original named plaintiff Julian Sancton was joined by 11 other named nonfiction-writer plaintiffs in this first amended complaint. In addition to adding new plaintiffs, the complaint included developments related to Sam Altman’s reinstatement at OpenAI that occurred since the first complaint was filed. The complaint alleged the same two causes of action:

Dec. 4, 2023 – Authors Guild plaintiffs filed amended complaint

Plaintiffs amended their complaint [1] to include Microsoft as an additional defendant. This amended complaint alleged the same three counts as the original, additionally accusing Microsoft of the same contributory copyright infringement allegations (Count 3) originally raised against OpenAI.&nbsp;

Nov. 21, 2023 – Sancton filed motion to relate Sancton and Authors Guild

Plaintiffs filed a motion to relate this case to <a href="https://www.bakerlaw.com/authors-guild-v-openai/" target="_blank" rel="noreferrer noopener">Authors Guild v. OpenAI</a>, No. 1:23-cv-08292.

Nov. 21, 2023 – Sancton filed complaint

In their putative class action complaint against OpenAI and Microsoft, Julian Sancton alleged that defendants infringed “a massive quantity” of copyrighted nonfiction works when they collaborated to create and monetize GPT-3, GPT-3.5, GPT-4, and GPT-4 Turbo models, including as the OpenAI ChatGPT and Microsoft Copilot tools. The complaint alleges two causes of action:

Sept. 19, 2023 – Authors Guild plaintiffs filed complaint against OpenAI

Authors Guild and 17 named authors, including John Grisham and George R.R. Martin, filed a putative class action complaint alleging that OpenAI included their books without permission in the training dataset for its GPT models, based on public statements by OpenAI and others regarding the contents of the dataset. The complaint alleged three causes of action:

Select Court Documents

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/12/ECF-1-Complaint.pdf" target="_blank" rel="noreferrer noopener">Sept. 19, 2023 – ECF 1 Authors Guild Complaint (1:23-cv-08292)</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-1-Complaint-1.pdf" target="_blank" rel="noreferrer noopener">Nov. 21, 2023 – ECF 1 Sancton Complaint (1:23-cv-10211)</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-3-Related-Case-Statement.pdf" target="_blank" rel="noreferrer noopener">Nov. 21, 2023 – ECF 3 Motion to Relate Sancton and Authors Guild</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-39-Amended-Complaint.pdf" target="_blank" rel="noreferrer noopener">Dec. 4, 2023 – ECF 39 Authors Guild Amended Complaint (1:23-cv-08292)</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-26-Amended-Complaint.pdf" target="_blank" rel="noreferrer noopener">Dec. 19, 2023 – ECF 26 First Amended Alter Complaint (1:23-cv-10211)</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-1-Basbanes-v-OpenAI.pdf" target="_blank" rel="noreferrer noopener">Jan. 05, 2024 - ECF 1 Basbanes Complaint</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-23-LETTER-addressed-to-Judge-Sidney-H.-Stein-from-Michael-P.-Richter-re-Consolidation-with-the-Authors-Guild-and-Sancton-Actions.pdf" target="_blank" rel="noreferrer noopener">Jan. 23, 2024 - ECF 23 Plaintiffs letter to court requesting consolidation</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-34-Court-Order.pdf" target="_blank" rel="noreferrer noopener">Jan. 26, 2024 – ECF 34 Court Order</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-35-OpenAI-Response-to-Plaintiffs-New-Class.pdf" target="_blank" rel="noreferrer noopener">Jan. 26, 2024 – ECF 35 OpenAI Response to Plaintiffs’ New Class Certification</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-37-Proposed-Schedule.pdf" target="_blank" rel="noreferrer noopener">Jan. 26, 2024 – ECF 37 Memo Endorsement</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-30-LETTER-addressed-to-Judge-Sidney-H.-Stein-from-Michael-P.-Richter-re-Consolidation-and-Steering-Committee.pdf" target="_blank" rel="noreferrer noopener">Feb. 05, 2024 - ECF 30 Author Guild response to motion to consolidate</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-47-First-Consolidated-Class-Action-Complaint.pdf" target="_blank" rel="noreferrer noopener">Feb. 06, 2024 – ECF 47 First Consolidated Class Action Complaint</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-32-Court-Order-re-Motion-to-Consolidate.pdf" target="_blank" rel="noreferrer noopener">Feb. 6, 2024 – ECF 32 Court Order re: Motion to Consolidate&nbsp; (1:24-cv-00084)</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-49-Tremblay-Silverman-and-Chabon-Plaintiffs-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Feb. 12, 2024 – ECF 49 Tremblay, Silverman, and Chabon Plaintiffs Motion to Intervene</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-51-Microsoft-Answer.pdf" target="_blank" rel="noreferrer noopener">Feb. 16, 2024 – ECF 51 Microsoft Answer</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-75-OpenAI-Answer.pdf" target="_blank" rel="noreferrer noopener"></a><a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-75-OpenAI-Answer.pdf" target="_blank" rel="noreferrer noopener">Feb. 16, 2024 – ECF 75 OpenAI Answer </a>(<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-67-OpenAI-Answer.pdf" target="_blank" rel="noreferrer noopener">refiled as ECF 67 on March 4</a>)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-35-Microsoft-Opposition-to-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Feb. 26, 2024 – ECF 79 Microsoft Opposition to Motion to Intervene</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-36-OpenAI-Response-to-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Feb. 26, 2024 – ECF 80 OpenAI Response to Motion to Intervene</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/03/ECF-81-Alter-and-Authors-Guild-Plaintiffs-Response-to-Microsofts-Opposition.pdf" target="_blank" rel="noreferrer noopener">Feb. 26, 2024 – ECF 81 Plaintiffs’ Response to [79] Microsoft’s Opposition to Third-Party Motion to Intervene</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/02/ECF-31-Fiction-and-nonfiction-author-plaintifjfs-response-to-Basbanes-Gage-Plaintiffs-motion-to-consolidate-and-seek-other-relief.pdf" target="_blank" rel="noreferrer noopener">ECF 31 Plaintiffs’ request for steering committee briefing</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-84-Order-Denying-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Apr. 1, 2024 – ECF 84 Order Denying Motion to Intervene</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/09/ECF-145-and-146-Notice-of-Voluntary-Dismissal-combined.pdf" target="_blank" rel="noreferrer noopener">July 30, 2024 – ECF 145 and 146 Notice of Voluntary Dismissal</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/09/ECF-150-Opposition-to-Voluntary-Dismissal.pdf" target="_blank" rel="noreferrer noopener">July 30, 2024 – ECF 150 Opposition to Voluntary Dismissal</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2025/01/ECF-107-Stipulation-and-Order.pdf" target="_blank" rel="noreferrer noopener">Sept. 30, 2024 – Stipulation and Order</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2025/01/ECF-120-Order.pdf" target="_blank" rel="noreferrer noopener">Oct. 31, 2024 – ECF 120 Order</a>