In a legal dispute with significant implications for artificial intelligence (AI) development and intellectual property rights, a US district judge in California has ruled in favor of OpenAI, largely dismissing claims raised by authors regarding the alleged unauthorized use of their works in ChatGPT, OpenAI’s popular language model.
Dismissal of Claims
Judge Araceli Martínez-Olguín dismissed the majority of claims brought forth by authors, including Sarah Silverman, Michael Chabon, and Paul Tremblay. The authors had alleged that ChatGPT was trained on pirated copies of their books without their permission, constituting copyright infringement and other violations.
Insufficient Evidence of Direct Copyright Infringement
Martínez-Olguín concluded that the authors failed to provide sufficient evidence to support their claims, except for direct copyright infringement. The judge highlighted that the authors did not demonstrate that ChatGPT outputs contained direct copies of their copyrighted books, which is necessary to establish claims of vicarious infringement.
Rejection of DMCA Violation Claims
The authors’ claims under the Digital Millennium Copyright Act (DMCA), alleging the removal of copyright management information (CMI) from training data, were also dismissed. Martínez-Olguín noted the absence of evidence indicating intentional removal of CMI by OpenAI and cited instances where ChatGPT referenced author names, suggesting the presence of CMI in the training data.
Permitted Claims and Path Forward
Martínez-Olguín allowed one claim under California’s unfair competition law to proceed, based on OpenAI’s alleged use of copyrighted works to train ChatGPT without authors’ permission. However, claims of negligence and unjust enrichment were dismissed due to the authors’ failure to provide evidence of intentional acts by OpenAI.
Potential for Amended Complaints
Authors have been given until March 13 to amend their arguments and pursue any dismissed claims. To strengthen their case, authors may need to provide examples of ChatGPT outputs similar to their works and evidence of intentional removal of CMI by OpenAI.
Conclusion: Continuing Legal Proceedings
The legal battle between authors and OpenAI over the alleged unauthorized use of copyrighted works in ChatGPT continues. With dismissed claims and permitted avenues for legal action, authors are expected to refine their arguments in pursuit of remedies for alleged copyright infringement and unfair business practices.
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