Delhi HC Rules OpenAI's Use Of ANI Data Isn't Copyright Infringement

Justice Amit Bansal pronounced the judgement stating that Open AI's act of storing ANI's literary works for training LLM falls under Section 52 of Copyright Act

OpenAI v ANI case
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Summary
Summary of this article
  • Delhi High Court ruled that OpenAI's usage ANI data is not copyright infringement

  • A bench of Justice Amit Bansal pronounced the judgement that it reserved on March 27

  • The court decided that OpenAI’s use of ANI’s data is ‘fair use’ in terms of Section 52 of the Copyright Act, 1957

The Delhi High Court on Friday ruled that OpenAI using the data of news agency ANI does not amount to copyright infringement.

A bench of Justice Amit Bansal pronounced the judgement that it reserved on March 27.

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"I have decided on the four issues (identified in the case), (issue number) 1 and 3 have a combined findings. On the issue of territorial jurisdiction, I have held in favour of the plaintiff (ANI)," Justice Bandal said, as per Bar and Bench.

"I am of the prima facie view that the Open AI's act of storing ANI's literary works for training LLM falls under section 52 and so, does not amount to infringement," he added.

What Were The Issued Framed?

The four issues identified in the matter by the court were to understand whether:

1. the storage of ANI's news coverage and data by OpenAI for training its chatbot ChatGPT would amount to copyright infringement or not,

2. the usage of copyrighted data and news in order to generate responses for ChatGPT's users would amount to copyright infringement,

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3. the OpenAI’s use of ANI’s data and news falls under the 'fair use' case of Section 52 of the Copyright Act, 1957, and

4. this court has jurisdiction.

What Did The Court Rule?

While pronouncing the judgement, the bench said that outputs and responses generated by OpenAI's ChatGPT using the Retrieval-Augmented Generation (RAG) technique does not amount to copyright infringement as the responses generated were not substantially similar to the original content published by ANI.

"Further, ANI has failed to satisfy this Court that any memorisation or regurgitation of ANI's copyrighted literary works has happened to the responses generated by ChatGPT," the court ruled, as per Bar and Bench.

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The bench also observed that granting an injunction would also hurt public interest.

"ANI has failed to make out a prima facie case for grant of interim injunction. Balance of convenience is also against grant of interim injunction," it added and dismissed the news agency's interim injunction plea.

The detailed copy of the court's order is awaited.

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