by Angela Dunning, Arminda Bepko, and Jessica Graham
From left to right: Angela Dunning, Arminda Bepko & Jessica Graham (photos courtesy of Cleary Gottlieb Steen & Hamilton LLP)
This week saw yet another California federal court dismiss copyright and related claims arising out of the training and output of a generative AI model in Tremblay v. OpenAI, Inc.,[1] a putative class action filed on behalf of a group of authors alleging that OpenAI infringed their copyrighted literary works by using them to train ChatGPT.[2] OpenAI moved to dismiss all claims against it, save the claim for direct copyright infringement, and the court largely sided with OpenAI.