Key holding or allegation
LG Munchen I held that reproducibly memorised protected lyrics in GPT-4/4o constituted copies embodied in the model, that TDM did not justify the persistent model-level reproduction found, and that specified outputs separately infringed.
Why it matters
One of the world's strongest direct judicial holdings that memorised protected expression within model parameters can constitute copyright reproduction.
Facts
GEMA alleged that protected song lyrics were memorised in OpenAI models and reproducible through prompts.
Issues before the court
Whether protected expression reproducibly embodied in model parameters constitutes reproduction, whether TDM exceptions extend to that model state, and whether outputs infringe.
What the court did not decide
First-instance judgment only; appeal remains pending and the holding depends on the factual finding of reproducible memorisation.
Procedural timeline
LG Munchen I
First-instance merits judgment: Reproducibly memorised protected lyrics in GPT-4/4o were held to constitute model-level reproductions; TDM did not justify the persistent reproduction found; specified outputs also infringed.