OpenAI's Alleged Role in Copyright Infringement and Removal of Copyright Management Information

DEFENDANTS’ COLLABORATION IN INFRINGING PLAINTIFF’S COPYRIGHT, UNLAWFULLY REMOVING COPYRIGHT MANAGEMENT INFORMATION, AND UNLAWFULLY DISTRIBUTING PLAINTIFF’S WORKS WITH COPYRIGHT MANAGEMENT INFORMATION REMOVED

101. Based on the publicly available information described above, including the admission from Microsoft’s CEO that “we have the data, we have everything,” Defendant Microsoft has created, without Plaintiff’s permission, its own copies of Plaintiff’s copyright protected works of journalism, including but not limited to the Registered Works.

102. Based on the publicly available information described above, including information showing that Defendant Microsoft created and hosted the data centers used to develop ChatGPT and information regarding Microsoft’s own Copilot, Defendant Microsoft intentionally removed author, title, copyright notice, and terms of use information from Plaintiff’s copyrighted works in creating ChatGPT and Copilot training sets.

103. Based on publicly available information regarding the relationship between Defendant Microsoft and the OpenAI Defendants, and Defendant Microsoft’s provision of database and computing resources to the OpenAI Defendants, Defendant Microsoft has shared copies of Plaintiff’s works from which author, title, copyright notice, and terms of use information had been removed, with the OpenAI Defendants as part of Defendants’ efforts to develop ChatGPT and Copilot.

104. Based on publicly available information regarding the working relationship between Defendant Microsoft and the OpenAI Defendants, including the creation of training sets by the OpenAI Defendants such as WebText and WebText2, the OpenAI Defendants have shared copies of Plaintiff’s works from which author, title, copyright notice, and terms of use information had been removed, with Defendant Microsoft as part of Defendants’ efforts to develop ChatGPT and Copilot.