AI Liability Complaint

DOE v. OPENAI, LP

🏛 U.S. District Court for the District of Columbia · 📅 2025-12-30

Issue

Whether OpenAI, Google, Microsoft, Meta, Nvidia, Anthropic, xAI, AWS, and Perplexity are liable for copyright infringement, trade secret misappropriation under 18 U.S.C. § 1836, civil RICO violations under 18 U.S.C. §§ 1962–1964, and related state and federal claims based on the alleged wholesale adoption of a pro se plaintiff's purported 2018 generative AI architectural framework.

What Happened

Plaintiff John Doe, a Maryland resident proceeding pro se through a court-appointed guardian and designated a "vulnerable adult" under Maryland law, filed this complaint on December 30, 2025 in the U.S. District Court for the District of Columbia against eleven named AI companies and their principals, plus up to ten million Doe defendants. Plaintiff alleges that a series of written works created between May 29, 2018 and December 30, 2021 constitute the sole documented origin point for internet-connected, universal-capability generative AI, and that all named defendants copied this framework in its entirety. The complaint seeks damages calculated at a "1,337x multiplier" on claimed cumulative AI revenues of $1.02–$3.06 trillion, requests summary judgment on liability, and invokes global enforcement under the Berne Convention and TRIPS; no judicial ruling has yet issued, as the docket reflects the case was filed the same day and remains unassigned.

Why It Matters

The complaint is a pro se filing asserting legally extraordinary claims — including a mathematically derived infringement probability of 10⁻⁴⁵ and the assertion that informal written descriptions of broad AI concepts constitute copyrightable expression sufficient to support trillion-dollar damages — and it is unlikely to survive threshold screening under Rule 12 or the copyright originality standard of *Feist Publications*; however, it illustrates a growing category of pro se litigation attempting to impose intellectual property and RICO liability on AI developers for the architecture of large language models, a question courts have not yet resolved on the merits.

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