Key holding or allegation
The court found allegations insufficient where plaintiffs could not plausibly connect their specific works to the actual training data of the challenged models.
Why it matters
Important U.S. pleading/evidence authority on training-data traceability.
Facts
Authors alleged use of books from broad open or shadow-library datasets in training particular LLMs.
Issues before the court
Whether general allegations about datasets plausibly established that plaintiffs' specific works were actually used to train the challenged models.
What the court did not decide
Does not decide whether training on a proven copyrighted work would infringe or be fair use.
Procedural timeline
U.S. District Court for the Northern District of California
Partial dismissal ruling: General allegations that works appeared in broad open or shadow-library datasets were insufficient without a plausible factual connection to the challenged models' actual training data.