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Part 14 - Count IV – Violation of 17 U.S.C. § 1202(b)(1) by OpenAI Defendants
The Center for Investigative Reporting Inc. v. OpenAI Court Filing, retrieved on June 27, 2024, is part of HackerNoon’s Legal PDF Series. You can jump to any part in this filing here. This part is 14 of 18.
Count IV – Violation of 17 U.S.C. § 1202(b)(1) by OpenAI Defendants
135. The above paragraphs are incorporated by reference into this Count.
136. Plaintiff is the owner of copyrighted works of journalism that contain author, title, copyright notice, and terms of use information.
137. Upon information and belief, the OpenAI Defendants created copies of Plaintiff’s works of journalism with author information removed and included them in training sets used to train ChatGPT.
138. Upon information and belief, the OpenAI Defendants created copies of Plaintiff’s works of journalism with title information removed and included them in training sets used to train ChatGPT.
139. Upon information and belief, the OpenAI Defendants created copies of Plaintiff’s works of journalism with copyright notice information removed and included them in training sets used to train ChatGPT.
140. Upon information and belief, the OpenAI Defendants created copies of Plaintiff’s works of journalism with terms of use information removed and included them in training sets used to train ChatGPT.
141. The OpenAI Defendants had reason to know that inclusion in their training sets of Plaintiff’s works of journalism without author, title, copyright notice, and terms of use information would induce ChatGPT to provide responses to users that incorporated material from Plaintiff’s copyright-protected works or regurgitated copyright-protected works verbatim or nearly verbatim.
142. The OpenAI Defendants had reason to know that inclusion in their training sets of Plaintiff’s works of journalism without author, title, copyright notice, and terms of use information would induce ChatGPT users to distribute or publish ChatGPT responses that utilized Plaintiff’s copyright-protected works of journalism that such users would not have distributed or published if they were aware of the author, title, copyright, or terms of use information.
143. The OpenAI Defendants had reason to know that inclusion in their training sets of Plaintiff’s works of journalism without author, title, copyright notice, and terms of use information would enable copyright infringement by ChatGPT and ChatGPT users.
144. The OpenAI Defendants had reason to know that inclusion in their training sets of Plaintiff’s works of journalism without author, title, copyright notice, and terms of use information would facilitate copyright infringement by ChatGPT and ChatGPT users.
145. The OpenAI Defendants had reason to know that inclusion in their training sets of Plaintiff’s works of journalism without author, title, copyright notice, and terms of use information would conceal copyright infringement by Defendants, ChatGPT, and ChatGPT users.
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