Summary
Some of the same plaintiffs from the OpenAI ChatGPT Litigation filed a similar complaint against Meta, alleging Meta’s unauthorized copying of the plaintiffs’ books for purposes of training LLaMA models constitutes copyright infringement.
What We’re Watching
Two months after the oral arguments hearing, Judge Vince Chhabria denied plaintiffs’ motion for partial summary judgment on fair use and granted Meta’s cross-motion and granted Meta’s motion for partial summary judgment on the DMCA claim. Authors lost their fair use argument in this landmark case, as they “fail[ed] to present meaningful evidence on the effect of training LLMs…with their books on the market for [AI-generated] books.” Judge Chhabria emphasized that his decision is not a precedent that applies to all such cases. As to the DMCA claim, Judge Chhabria cited to his earlier order to reason that because “Meta’s copying was not an infringement,” Meta’s “removal of CMI could not have furthered an act of infringement.”