Elon Musk's Lawsuit Unveils OpenAI’s Complex Corporate Network

PARTIES

6. Plaintiff Elon Musk is an individual, citizen, and resident of Texas.

   
   

7. Plaintiff is informed and believes and thereon alleges that Defendant Samuel Altman is a resident of San Francisco, California.

   
   

8. Plaintiff is informed and believes and thereon alleges that Defendant Gregory Brockman is a resident of San Francisco, California.

   
   

9. OpenAI, Inc. is a registered non-profit organization incorporated under the laws of Delaware on December 8, 2015. OpenAI, Inc. is registered as an out-of-state corporation with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

   
   

10. OpenAI, L.P. is a limited partnership formed under the laws of Delaware on September 19, 2018, originally as SummerSafe, L.P. On information and belief, on January 23, 2023 OpenAI, L.P. was converted to OpenAI OpCo, LLC. OpenAI, L.P. is registered as an out-of-state limited partnership with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

    
    

11. OpenAI, L.L.C. is a limited liability company formed in Delaware on September 17, 2020. OpenAI, L.L.C. maintains its principal place of business in California.

    
    

12. OpenAI GP, L.L.C. is a limited liability company formed in Delaware on September 19, 2018. OpenAI GP, L.L.C is registered as an out-ofstate limited liability company registered with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

    
    

13. OpenAI OpCo, LLC is a limited liability company formed in Delaware on September 19, 2018 as OpenAI, L.P, but was later converted on January 23, 2023 to OpenAI OpCo, LLC. OpenAI OpCo, LLC is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 1960 Bryant Street, San Francisco, CA 94110.

14. OpenAI Global, LLC is a limited liability company formed in Delaware on December 28, 2022. OpenAI Global, LLC is registered as an outof-state limited liability company with the California Secretary of State and has its principal place of business at 1960 Bryant Street, San Francisco, CA 94110.

15. OAI Corporation, LLC is a limited liability company formed in Delaware. OAI Corporation, LLC maintains its principal place of business in California.

16. OpenAI Holdings, LLC is a limited liability company formed in Delaware on March 17, 2023. OpenAI Holdings, LLC is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 1960 Bryant Street, San Francisco, CA 94110.

17. OpenAI Investment LLC is a limited liability company formed in Delaware on February 6, 2023. Plaintiff is informed and believes and thereon alleges that OpenAI Investment LLC also maintains its principal place of business in San Francisco, California.

18. OpenAI Startup Fund Management, LLC is a limited liability company formed in Delaware on July 16, 2021. OpenAI Startup Fund Management, LLC is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

19. OpenAI Startup Fund GP I, L.L.C. is a limited liability company formed in Delaware on July 28, 2021. OpenAI Startup Fund GP I, L.L.C. is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

20. OpenAI Startup Fund I, L.P. is a limited partnership formed in Delaware on July 28, 2021. OpenAI Startup Fund I, L.P. is registered as an out-of-state limited partnership with the California Secretary of State and has its principal place of business at 3180 18th Street, San Francisco, CA 94110.

21. OpenAI Startup Fund SPV GP I, L.L.C. is a limited liability company formed in Delaware on December 5, 2023. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV GP I, L.L.C. maintains its principal place of business in San Francisco, California.

22. OpenAI Startup Fund SPV GP II, L.L.C. is a limited liability company formed in Delaware on April 4, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV GP II, L.L.C. maintains its principal place of business in San Francisco, California.

23. OpenAI Startup Fund SPV GP III, L.L.C. is a limited liability company formed in Delaware on April 4, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV GP III, L.L.C. maintains its principal place of business in San Francisco, California.

24. OpenAI Startup Fund SPV GP IV, L.L.C. is a limited liability company formed in Delaware on May 9, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV GP IV, L.L.C. maintains its principal place of business in San Francisco, California.

25. OpenAI Startup Fund SPV I, L.P. is a limited partnership formed in Delaware on December 5, 2023. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV I, L.P. maintains its principal place of business in San Francisco, California.

26. OpenAI Startup Fund SPV II, L.P. is a limited partnership formed in Delaware on April 4, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV II, L.P. maintains its principal place of business in San Francisco, California.

27. OpenAI Startup Fund SPV III, L.P. is a limited partnership formed in Delaware on April 4, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV III, L.P. maintains its principal place of business in San Francisco, California.

28. OpenAI Startup Fund SPV IV, L.P. is a limited partnership formed in Delaware on May 9, 2024. Plaintiff is informed and believes and thereon alleges that OpenAI Startup Fund SPV IV, L.P. maintains its principal place of business in San Francisco, California.

29. Aestas Management Company, LLC, is a Delaware limited liability company formed in Delaware on February 10, 2023. Aestas Management Company, LLC is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 1960 Bryant Street, San Francisco, CA 94110.

30. Aestas, LLC is a limited liability company formed in Delaware on September 19, 2018. Aestas, LLC is registered as an out-of-state limited liability company with the California Secretary of State and has its principal place of business at 1960 Bryant Street, San Francisco, CA 94110.

31. Plaintiff is informed and believes and based thereon alleges that the fictitiously named defendants captioned hereinabove as Does 1 through 10, inclusive, and each of them, were in some manner responsible or legally liable for the actions, damages, events, transactions, and circumstances alleged herein. The true names and capacities of such fictitiously named defendants, whether individual, corporate, associate, or otherwise are presently unknown to Plaintiff, and Plaintiff will amend this Complaint to assert the true names and capacities of such fictitiously named defendants when they have been ascertained. For convenience, each reference herein to the named Defendants shall also refer to the Doe defendants and each of them.