Skip to content

Generated Source Mirror

This page is generated from the source Markdown file so it can be viewed inside the MkDocs site.

📝 Page Status: Draft — sourced but not yet reviewed

  • Status: draft
  • Sources: 1
  • Relationships: 4
  • Research debt items: 3

In re Google Generative AI Copyright Litigation

Summary

In re Google Generative AI Copyright Litigation, Master File No. 5:23-cv-03440 (N.D. Cal.), consolidates putative class actions by authors and visual artists alleging that Google LLC trained generative models on copyrighted works. On September 11, 2025, Judge Eumi K. Lee dismissed with prejudice direct-infringement claims as to specified models that the complaint did not factually connect to the training datasets, and dismissed vicarious claims against Alphabet Inc. Claims concerning Bard, Gemini, Imagen, and related large-language and Imagen models were not dismissed on that ground. The order is not a fair-use holding.

Verified Facts

  • The consolidated action originated as Leovy v. Google LLC, No. 23-cv-03440, filed July 11, 2023, and Zhang v. Google LLC, No. 24-cv-02531, filed April 26, 2024, on behalf of visual artists including photographers, cartoonists, and illustrators. After reassignment, the court consolidated the cases for all trial and pretrial proceedings under Master File No. 23-cv-03440-EKL, captioned In re Google Generative AI Copyright Litigation.1
  • The consolidated amended complaint alleged that Google and Alphabet “infringed millions of registered copyrighted works” to build and train Google’s generative AI models. Plaintiffs alleged training of large language models including PaLM, GLaM, LaMDA, Bard, and Gemini on overlapping datasets including Infiniset/C4, and training of Imagen text-to-image models on LAION-400M and LAION-5B.1
  • On September 11, 2025, the court granted Google’s motion to dismiss in part, without leave to amend as to the dismissed claims. Direct-infringement claims relating to Codey, Chirp, Veo, MedLM, LearnLM, SecLM, Gemma, CodeGemma, RecurrentGemma, and PaliGemma were dismissed with prejudice. Vicarious copyright-infringement claims against Alphabet were dismissed with prejudice.1
  • The court found that the complaint alleged training of PaLM, GLaM, LaMDA, Bard, Gemini, and Imagen on datasets said to include copyrighted works, and it rejected Google’s attempt to dismiss named plaintiff Sarah Andersen’s claims at the pleading stage on registration/publication grounds as too fact-bound.1
  • Plaintiffs were ordered to file a second amended consolidated complaint within 14 days limited to amending the class definition consistent with a prior order striking class allegations, without adding new claims, parties, or other allegations.1

Historical Context

This is the leading U.S. class action against Google’s generative products. Image-training allegations overlap the LAION datasets also at issue in Andersen v. Stability AI and Kneschke v. LAION, but those cases have different defendants and different legal systems.1

Jurisdiction: Northern District of California. Authority level: Rule 12(b)(6) order. The court did not decide § 107. It required model-by-model factual allegations connecting training datasets to copyrighted works, and it refused to treat ordinary parent-subsidiary control as vicarious copyright liability.1

This page does not treat later class-certification or discovery orders as merits holdings.

Relationships

  • CASE-IN-RE-GOOGLE-GEN-AI cites SRC-GOOGLE-GEN-AI-MTD-2025.
  • CASE-IN-RE-GOOGLE-GEN-AI related_to CASE-ANDERSEN-V-STABILITY.
  • CASE-IN-RE-GOOGLE-GEN-AI related_to CASE-KNESCHKE-V-LAION.
  • CASE-IN-RE-GOOGLE-GEN-AI related_to TOPIC-AI-COPYRIGHT.

Sources

  1. SRC-GOOGLE-GEN-AI-MTD-2025: Order granting motion to dismiss in part (Sept. 11, 2025).

Research Debt

  • Add the second amended consolidated complaint and any class-certification order from those filings.
  • Add later discovery orders only for scheduling facts that OIR needs.
  • Named plaintiff overlap with Andersen is noted in the 2025 order; do not merge the dockets.

Document metadata

  • Decision date: 2025-09-11
  • Last verified: 2026-09-02

  1. SRC-GOOGLE-GEN-AI-MTD-2025 — Order (Sept. 11, 2025). Primary for history, alleged theories, and holdings. ↩↩↩↩↩↩↩