Carreyrou v. Anthropic PBC
Issue
Whether Anthropic, Google, Meta, xAI, Perplexity, Apple, NVIDIA, and OpenAI are liable under the Copyright Act for willful infringement by downloading plaintiffs' copyrighted books from shadow libraries (including LibGen, Z-Library, Anna's Archive, and The Pile/Books3) and reproducing those works during LLM training, preprocessing, and fine-tuning without license or permission.
What Happened
Plaintiffs — individual authors and a corporate plaintiff — filed this amended complaint in the Northern District of California against thirteen AI and technology defendants, alleging that each defendant obtained pirated copies of plaintiffs' registered, copyrighted books from shadow-library websites and made additional unauthorized reproductions during LLM ingestion, preprocessing, and iterative training. Plaintiffs allege the infringement was willful, citing internal industry warnings that these sources were illegal and defendants' deliberate decision to proceed for competitive advantage. Plaintiffs expressly declined class-action treatment, invoking their right under the Copyright Act to pursue individualized statutory damages — up to $150,000 per willfully infringed work — and a jury determination of willfulness, contrasting their approach with a pending class settlement they characterize as yielding approximately $3,000 per work.
Why It Matters
This complaint advances the unsettled question of whether the use of pirated training datasets constitutes willful copyright infringement by LLM developers at each stage of the AI development pipeline, potentially establishing that liability attaches not only at initial download but also at preprocessing, deduplication, and iterative fine-tuning; the plaintiffs' deliberate individual-action strategy, if successful, could foreclose industry efforts to resolve mass AI copyright claims through low-value class settlements.
Related Filings
Other proceedings in the same litigation tracked by this monitor.
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