---
id: SAFE-IP-001
title: "Copyright and Intellectual Property"
alternative_names:
  - "AI and Copyright"
  - "Generative AI Copyright Litigation"
  - "AI Training Data and Fair Use"
category: "Safety & Governance → Ethics and Law → Intellectual Property"
volume: VIII
chapter: 47
entry_type: "Standard Article"
level: 3
status: "Draft"
last_reviewed: 2026-10-18
version: "0.2.0"
prerequisites:
  - "CAP-GENAI-001"
related_entries:
  - "SAFE-PRIV-001"
  - "SAFE-ETHICS-001"
  - "TECH-DATA-001"
  - "GOV-LAW-001"
  - "GOV-EU-001"
  - "GOV-US-001"
  - "APP-MEDIA-001"
---

# Copyright and Intellectual Property

> **Scope and legal notice.** This is an encyclopedia entry, not legal advice. Legal statements are dated 2026-10-18 and tagged by jurisdiction (United States, United Kingdom, Germany, European Union). Many cases below are on appeal or unresolved. Where the court's own text (or docket) was read for this draft it is said so; other details are drawn from law-firm and press summaries and are marked "secondary". Outcomes differ by jurisdiction and by facts.

## 1. Concise Definition
**Copyright and intellectual property (IP) in AI** concerns two sets of legal questions: whether copying protected works to train AI models, or models reproducing such works in outputs, infringes the rights of the owners; and whether AI-generated material, or AI-assisted inventions, can themselves be protected by copyright or patent. The answers are set by national law and are being decided case by case.

## 2. Overview & Significance
Generative models (see [CAP-GENAI-001]) are trained on very large collections of text, images, code, music and video, much of it protected. Rights holders have sued developers in several countries. The disputes turn on different doctrines in each system: the open-ended, four-factor *fair use* defence in US law; closed lists of *exceptions* (for example text-and-data-mining exceptions) in EU member states and the UK; and, in the UK, whether a trained model is an "infringing copy". Because the questions are new and first-instance courts have not agreed, the law is unsettled. A second set of questions concerns authorship: US law, as applied by the courts so far, requires a human author.

Privacy aspects of training data are covered in [SAFE-PRIV-001]; dataset provenance in [TECH-DATA-001]; creative-industry effects in [APP-MEDIA-001].

## 3. Historical Development
Before generative AI, copyright disputes over machine copying concerned search engines and digitisation, decided largely under US fair use. An early US ruling on fair use for AI training data was *Thomson Reuters v. Ross Intelligence*, decided on 11 February 2025 by Judge Bibas (sitting by designation in the District of Delaware) in favour of Thomson Reuters, in a case involving a non-generative legal-search tool; the Third Circuit affirmed on 29-30 September 2026, reported as the first federal appellate decision on fair use in AI training. In June 2025 two judges in the Northern District of California reached more favourable conclusions for developers on training itself (*Bartz v. Anthropic*, 23 June 2025; *Kadrey v. Meta*, 25 June 2025). In 2025 outside the US, the UK High Court decided *Getty Images v Stability AI* (4 November 2025), a Munich court decided *GEMA v OpenAI* (11 November 2025) and the Hamburg appeal court decided *Kneschke v LAION* (10 December 2025). Section 6 summarises each.

## 4. Technical / Conceptual Explanation

### 4.1 Where copying occurs
Copyright analysis distinguishes (a) **copying in building the training set** (downloading and storing works); (b) **training**, in which model parameters are adjusted; (c) **memorisation inside the model**, where parameters may encode portions of works; and (d) **outputs** that may reproduce or resemble protected works. Technical evidence of extractable memorisation (Carlini et al., 2021; Nasr et al., 2023; see [SAFE-SEC-001] and [SAFE-PRIV-001]) bears on (c) and (d); it does not by itself determine the legal characterisation.

### 4.2 US fair use
17 U.S.C. section 107 lists four factors for fair use: the purpose and character of the use, including whether it is commercial; the nature of the copyrighted work; the amount and substantiality of the portion used; and the effect of the use on the potential market for or value of the work (U.S. Copyright Office, Title 17). Courts weigh the factors case by case. In AI cases, the debate centres on whether training is "transformative" and on market harm, including a "market dilution" theory in which AI outputs compete with the authors' works without copying them.

### 4.3 EU text-and-data-mining exception and AI Act duties
The EU AI Act requires providers of general-purpose AI models to "put in place a policy to comply with Union law on copyright and related rights", including honouring rights holders' text-and-data-mining opt-outs under Article 4(3) of the 2019 copyright directive, and to "draw up and make publicly available a sufficiently detailed summary about the content used for training" using an AI Office template (Regulation (EU) 2024/1689, Art. 53(1)(c)-(d); quoted wording checked against the Official Journal text, read 2026-10-18). Application dates of the AI Act were amended in 2026; see [GOV-EU-001].

## 5. Types, Components & Classifications
| Question | United States | United Kingdom | Germany / EU |
| :--- | :--- | :--- | :--- |
| Is training on protected works lawful? | Case-by-case fair use; district courts split on facts; first appellate ruling (*Ross*, non-generative) against fair use | Not decided on training in *Getty* (training claim abandoned; see below) | TDM exceptions with opt-out; first-instance rulings differ |
| Does the model itself contain copies? | Not resolved at appellate level for generative models | *Getty*: model not an "infringing copy" (first instance; permission to appeal granted) | *GEMA*: memorisation in model parameters treated as reproduction (first instance) |
| Are outputs infringing? | Fact-specific | Output claim abandoned in *Getty* (not decided); trade mark claims partly succeeded | *GEMA*: lyric outputs infringing (first instance) |
| Can AI be an author? | No: human authorship required (D.C. Cir.; cert. denied 2 March 2026) | Patent: inventor must be a natural person (UKSC 2023); the UK government has proposed removing protection for wholly computer-generated works (March 2026 report) | Not covered here |

## 6. Applications & Concrete Examples
Each item gives jurisdiction, court, date and status as of 2026-10-18. Items marked "secondary" rely on law-firm or press summaries; items marked "primary" cite a court document that was read.

**United States**
- *Thomson Reuters v. Ross Intelligence* (D. Del., No. 1:20-cv-613, Judge Bibas, 11 February 2025): partial summary judgment for Thomson Reuters on direct infringement of 2,243 Westlaw headnotes and rejection of the fair use defence; the tool was not generative AI (secondary). On interlocutory appeal (3d Cir. No. 25-2153; argument reported for 11 June 2026) the Third Circuit panel (Montgomery-Reeves, Restrepo, Bove, JJ.) affirmed. The opinion carries a docket stamp of 30 September 2026 (primary, docket stamp only); press reports date a first, sealed version to 29 September 2026. Per press reports of the opinion, it held the headnotes copyrightable, held ROSS's use "minimally transformative at best" and not fair use, found market harm including to a market for licensing headnotes as AI training data, and distinguished ROSS's non-generative system from LLMs (secondary: Courthouse News, LawNext). ROSS has said it will seek en banc rehearing and Supreme Court review (secondary); the case returns to the district court on remaining claims. [VERIFICATION NEEDED: opinion text beyond the docket stamp was not read; precedential status and whether rehearing was sought.]
- *Bartz v. Anthropic PBC* (N.D. Cal., No. C 24-05417 WHA, Judge Alsup, Order on Fair Use, 23 June 2025; primary, order read): the court held that using the books to train Claude was "exceedingly transformative" and a fair use; that Anthropic's digitising of print books it had purchased was also a fair use (for a different reason, format shifting of lawfully owned copies); and it denied summary judgment on the central library built from pirated copies, ordering a trial on that library and damages. The class action then settled for USD 1.5 billion (plus interest) and the court (Judge Araceli Martinez-Olguin, successor to Judge Alsup) gave final approval on 20 July 2026, with a fee award of about USD 101.6 million (Authors Guild report; Jurist; secondary). Reports give roughly 480,000 works; counts vary. Because it settled, it sets no binding precedent. [VERIFICATION NEEDED: the approval order itself was not read.]
- *Kadrey v. Meta Platforms* (N.D. Cal., No. 23-cv-03417-VC, Judge Chhabria, order of 25 June 2025; primary, order read): summary judgment for Meta on fair use for these thirteen authors on the record before the court. The court said plaintiffs had presented no meaningful evidence of market dilution, and wrote that the ruling "stands only for the proposition that these plaintiffs made the wrong arguments and failed to develop a record in support of the right one", not that Meta's use of copyrighted material to train its models is lawful. A separate claim about distribution during torrenting continued; a summary judgment hearing on it was reported as set for 25 February 2027 (secondary).
- *New York Times v. Microsoft and OpenAI* (S.D.N.Y., No. 1:23-cv-11195, Judge Stein; coordinated with other cases in MDL No. 25-md-03143, *In re OpenAI, Inc. Copyright Infringement Litigation*): no ruling on fair use reported. Cross-motions for summary judgment were filed on 4 September 2026 (secondary: litigation trackers and press); reply dates are reported as 6 or 20 November 2026 and no trial date is set. The US Department of Justice has filed a statement of interest supporting OpenAI's fair use position (secondary). [VERIFICATION NEEDED: briefing schedule; dockets were not opened.]
- *Thaler v. Perlmutter* (D.C. Cir. No. 23-5233, 18 March 2025): the Copyright Act requires human authorship; rehearing was denied on 12 May 2025 and the Supreme Court denied certiorari on 2 March 2026 (No. 25-449) (primary: Supreme Court docket page). Certiorari denial is not a merits ruling. The U.S. Copyright Office report *Copyright and Artificial Intelligence* has three parts: Digital Replicas (31 July 2024), Copyrightability (29 January 2025) and Generative AI Training (pre-publication version of 9 May 2025; the Office's index page, read 2026-10-18, still describes a final version as to come) (U.S. Copyright Office, 2025).
- *Thaler v. Vidal* (Fed. Cir., No. 2021-2347, 5 August 2022; 43 F.4th 1207): inventors under the Patent Act must be natural persons (secondary: case reporter listing and commentary).

**United Kingdom**
- *Getty Images v Stability AI* [2025] EWHC 2863 (Ch) (High Court, Mrs Justice Joanna Smith, 4 November 2025; primary, judgment text read via the National Archives). Getty's training claim was abandoned because there was no evidence that training took place in the UK, and its outputs claim was abandoned because the relevant prompts were blocked (para 9). The court dismissed the secondary-infringement claim: an "article" may be intangible, but an AI model that does not store or reproduce any copyright works is not an "infringing copy" under ss. 22-23 CDPA, and Stable Diffusion is such a model (para 758(viii)). Getty succeeded in part on trade mark infringement (iStock watermarks under s. 10(1) and 10(2) for v1.x; Getty Images watermarks under s. 10(2) for v2.x), failed under s. 10(3), and the court declined to decide passing off (para 758). At a consequentials hearing in December 2025 Getty was granted permission to appeal on the secondary-infringement point (sources give 16 or 17 December 2025; secondary: CMS, Burges Salmon). I found no listed Court of Appeal hearing date or decision. [VERIFICATION NEEDED: appeal listing and outcome; whether Stability sought permission on the trade mark findings.]
- *Thaler v Comptroller-General of Patents, Designs and Trade Marks* [2023] UKSC 49 (UK Supreme Court, 20 December 2023): an inventor under the Patents Act 1977 must be a natural person (neutral citation and date: Supreme Court case page; holding: secondary summary).
- *Government policy.* On 18 March 2026 the UK Government published its report on copyright and AI under section 136 of the Data (Use and Access) Act 2025, with an economic impact assessment under section 135. It states that a broad copyright exception with an opt-out "is no longer the government's preferred way forward", and sets out further evidence-gathering and monitoring rather than legislation; it also proposes removing protection for wholly computer-generated works while keeping protection for AI-assisted works (primary, gov.uk report page; first 100,000 characters read).

**Germany**
- *GEMA v OpenAI* (Regional Court Munich I, 42 O 14139/24, 11 November 2025): per commentary, memorisation of song lyrics in model parameters was held to be reproduction, the TDM exception did not cover it, and outputs of lyrics infringed; OpenAI as model operator was held responsible. First instance. OpenAI's appeal is reported as pending at the Higher Regional Court Munich (reported docket 6 U 3662/25 e) (secondary: Morgan Lewis, William Fry, Bird & Bird). [VERIFICATION NEEDED: appeal docket and hearing date.]
- *Kneschke v LAION* (Regional Court Hamburg, 27 September 2024; Higher Regional Court Hamburg, 10 December 2025, 5 U 104/24): both courts ruled for LAION. The appeal court reportedly relied on the TDM exception in section 44b of the German Copyright Act for the automated image-description matching and, additionally, on the scientific-research exception in section 60d for a non-commercial research body; it held that a rights holder's reservation must be machine-readable and that the plaintiff's natural-language reservation was not, and it limited its reasoning to dataset creation, not later training (secondary: Morgan Lewis, ELBKANZLEI; judgment text not read). It admitted a further appeal; that appeal is pending at the Federal Court of Justice (I ZR 281/25), which heard it on 3 September 2026, is reported to have signalled a referral of questions to the CJEU, and has a pronouncement date reported as 17 December 2026 (secondary: BFF report). [VERIFICATION NEEDED: BGH outcome and whether a CJEU referral is made.]
- *Like Company v Google Ireland* (CJEU, C-250/25): a Hungarian referral from April 2025 asks whether LLM training and chatbot outputs involve reproduction and communication to the public and whether the TDM exception applies. A public hearing was reported for 10 March 2026; I found no judgment (secondary). [VERIFICATION NEEDED: current status on curia.europa.eu.]

## 7. Advantages, Limitations & Unresolved Questions
- **Divergent first-instance outcomes.** US district courts reached different results on training (*Bartz*, *Kadrey* for developers on the records before them; *Ross* against, on a non-generative tool, now affirmed by the Third Circuit); UK and German courts differ on the status of models. No court of final appeal has decided the central training question for generative AI.
- **Source of the works matters.** In *Bartz*, the court distinguished training use from the building of a permanent library from pirated copies, which the fair use ruling on training did not excuse; this has practical consequences for data acquisition.
- **Market harm theories.** Whether outputs that compete without copying (market dilution) defeat fair use is open (*Kadrey*, primary: the judge described the theory as potentially winning but unproven on that record).
- **Opt-out mechanics.** The Hamburg appeal court's reported requirement of machine-readable reservations affects how rights holders can exclude their works; the UK Government has said an opt-out exception is no longer its preferred option.
- **Licensing.** Reported settlements and licences do not establish legal rules.
- **Authorship.** Human-authorship requirements leave the status of works with substantial but partial AI contribution to case-by-case analysis; the Copyright Office's Part 2 report (29 January 2025) concludes that, given currently available technology, prompts alone do not provide sufficient human control to make users the authors of AI output, while human-authored input, and human selection, arrangement or modification of AI output, can be protected, assessed case by case (primary, report text read).
- **Criminal, contract and terms-of-service issues** (for example scraping terms) are outside this draft.

## 8. Current State of Knowledge
As of 2026-10-18:
- There is **no settled rule** on whether training generative models on copyrighted works is lawful. This is **Contested** and varies by jurisdiction.
- The Third Circuit affirmed the rejection of a fair-use defence in *Ross* (non-generative AI) on 29-30 September 2026; the panel reportedly distinguished generative models, so this does not directly resolve generative training, and ROSS has said it will seek rehearing and Supreme Court review. **Well Supported** as to the Third Circuit's ruling; its reach for generative AI is **Contested** (opinion text beyond the docket stamp not read).
- The proposition that US copyright requires human authorship is **Well Supported** by appellate authority (*Thaler v. Perlmutter*), with certiorari denied; this is a statement about works generated without human authorial contribution, not about AI-assisted works generally.
- The proposition that inventors must be natural persons under UK and US patent law is **Well Supported** by apex or appellate rulings (*Thaler* cases; secondary).
- Statutory transparency and opt-out duties for general-purpose AI model providers exist in EU law (AI Act Art. 53).
- In the UK, no statutory text-and-data-mining reform for AI training has been enacted; the Government's March 2026 report defers action.

## 9. Future Trajectory & Strategic Outlook
This section contains no registered forecasts; outcomes of pending litigation are not predicted. Observed open points:
- **Near-term (0-3 years).** Appeals in *Getty* (UK), possible rehearing or certiorari in *Ross*, the appeal in *GEMA* and the Federal Court of Justice decision in *Kneschke* (Germany), the CJEU case *Like Company*, and district-court proceedings such as *NYT* (summary judgment pending) may clarify whether models contain copies and how fair use applies.
- **Medium-term (3-10 years).** Legislative responses (licensing, opt-out registries, transparency duties) are possible but not established.
- **Long-term (10+ years).** The status of increasingly autonomous AI creation under authorship rules is unresolved.

## 10. Related Entries & Knowledge Graph
- **Foundational Concepts**:
  - [[CAP-GENAI-001] Generative AI](../vol04_capabilities/CAP-GENAI-001_generative_ai.md): The systems whose training and outputs are at issue.
- **Related Methods & Technologies**:
  - [[TECH-DATA-001] Training Data, Contamination and Provenance](../vol03_technical/TECH-DATA-001_training_data_contamination_and_provenance.md): Data sourcing and documentation.
  - [[SAFE-PRIV-001] Privacy and Data Protection in AI](./SAFE-PRIV-001_privacy_and_data_protection_in_ai.md): Parallel questions on personal data in training sets.
  - [[SAFE-SEC-001] AI Security](./SAFE-SEC-001_ai_security_prompt_injection_poisoning_extraction.md): Extraction attacks and memorisation.
  - [[SAFE-ETHICS-001] AI Ethics, Bias and Fairness](./SAFE-ETHICS-001_ai_ethics_bias_and_fairness.md): Ethical dimensions of creative labour and consent.
  - [[APP-MEDIA-001] AI in Media and Creative Industries](../vol07_applications/APP-MEDIA-001_ai_in_media_and_creative_industries.md): Industry effects.
- **Advanced Implications & Future Trajectories**:
  - [[GOV-LAW-001] Global AI Governance & Regulation](./GOV-LAW-001_ai_governance.md): Overview of legal responses.
  - [[GOV-EU-001] The EU AI Act](./GOV-EU-001_the_eu_ai_act.md): Copyright-related duties and dates.
  - [[GOV-US-001] United States AI Policy](./GOV-US-001_united_states_ai_policy.md): US policy context.

## 11. References & Foundational Literature
**Primary and official sources**
1. U.S. Copyright Office. *Title 17, United States Code*, chapter 1, section 107. https://www.copyright.gov/title17/92chap1.html. [Four fair use factors; read 2026-10-18.]
2. U.S. Copyright Office. (2024-2025). *Copyright and Artificial Intelligence* (Parts 1-3). https://www.copyright.gov/ai/. [Part 1 31 July 2024; Part 2 29 January 2025 (text read 2026-10-18); Part 3 pre-publication 9 May 2025, not read beyond the index page.]
3. High Court of Justice (England and Wales), Business and Property Courts. (2025). *Getty Images (US) Inc. & Ors v Stability AI Ltd* [2025] EWHC 2863 (Ch), Joanna Smith J, 4 November 2025. https://www.judiciary.uk/judgments/getty-images-v-stability-ai/. [Citation, judge and date confirmed on the judiciary page; conclusions (para 758) read in the full judgment at https://caselaw.nationalarchives.gov.uk/ewhc/ch/2025/2863, 2026-10-18.]
4. European Union. (2024). *Regulation (EU) 2024/1689 (Artificial Intelligence Act)*, Art. 53(1)(c)-(d). https://eur-lex.europa.eu/eli/reg/2024/1689/oj (Official Journal text of Art. 53(1)(c)-(d) read 2026-10-18). [Copyright policy and training-content summary duties.]

**Court decisions known through secondary sources (primary texts not read)**
6. *Thomson Reuters Enterprise Centre GmbH v. Ross Intelligence Inc.*, No. 1:20-cv-613 (D. Del. Feb. 11, 2025) and No. 25-2153 (3d Cir., filed 30 September 2026, Doc. 214). [Sources: Venable, Jenner & Block and Goodwin client alerts on the 2025 ruling; Courthouse News (30 September 2026) and LawNext (October 2026) on the appeal; docket stamp of the opinion PDF read.]
7. *Bartz v. Anthropic PBC*, No. 3:24-cv-05417 (N.D. Cal. June 23, 2025), Order on Fair Use, Doc. 231 (read via govinfo.gov); class settlement. [Order read in full for the quoted points; final approval (20 July 2026) from Authors Guild and Jurist reports.]
8. *Kadrey v. Meta Platforms, Inc.*, No. 23-cv-03417-VC (N.D. Cal. June 25, 2025), Doc. 598. [Order read via CourtListener; later schedule from a docket-tracking blog.]
9. *In re OpenAI copyright litigation / New York Times Co. v. Microsoft Corp.* (S.D.N.Y.; MDL No. 1:25-md-03143). [Sources: litigation trackers and press, October 2026; dockets not opened.]
10. *Thaler v. Perlmutter*, No. 23-5233 (D.C. Cir. March 18, 2025); cert. denied No. 25-449 (2 March 2026). [Supreme Court docket page, read 2026-10-18.]
11. *Thaler v. Vidal*, No. 2021-2347 (Fed. Cir. Aug. 5, 2022); *Thaler v Comptroller-General of Patents, Designs and Trade Marks* [2023] UKSC 49 (20 December 2023). [Supreme Court case page and law-report listings; 43 F.4th 1207 for the Federal Circuit.]
12. *GEMA v OpenAI*, Landgericht München I, 42 O 14139/24 (11 November 2025). [Sources: Morgan Lewis, Bird & Bird and William Fry commentary.]
13. *Kneschke v LAION*, LG Hamburg (27 September 2024) and OLG Hamburg, 5 U 104/24 (10 December 2025). [Sources: Morgan Lewis, ELBKANZLEI and BFF commentary; BGH docket I ZR 281/25.]
14. Getty permission to appeal (December 2025). [Sources: CMS and Burges Salmon commentary.]

17. UK Government (DSIT). (2026). *Report on Copyright and Artificial Intelligence* (18 March 2026, under s. 136 Data (Use and Access) Act 2025). https://www.gov.uk/government/publications/report-and-impact-assessment-on-copyright-and-artificial-intelligence/report-on-copyright-and-artificial-intelligence. [UK Government position on AI training and copyright.]
18. *Like Company v Google Ireland*, CJEU C-250/25 (pending). [Source: secondary summaries; not checked on curia.europa.eu.]

**Technical literature**
15. Carlini, N., Tramèr, F., Wallace, E., Jagielski, M., Herbert-Voss, A., Lee, K., et al. (2021). *Extracting Training Data from Large Language Models*. arXiv:2012.07805. [Verbatim extraction; technical background for memorisation.]
16. Nasr, M., Carlini, N., Hayase, J., Jagielski, M., Cooper, A. F., Ippolito, D., et al. (2023). *Scalable Extraction of Training Data from (Production) Language Models*. arXiv:2311.17035. [Extraction from production models including aligned ones.]

## 12. Evidential Classification Matrix
| Section / Claim | Evidence Category | Supporting Source | Confidence / Status |
| :--- | :--- | :--- | :--- |
| Fair use has four statutory factors | Established | Ref 1 | High |
| Human authorship required for US copyright (appellate) | Well Supported | Ref 10 | High (cert. denied per Supreme Court docket) |
| Inventors must be natural persons (US, UK patents) | Well Supported | Ref 11 | Moderate-High (secondary) |
| Training on books held fair use (district court, summary judgment) | Preliminary (first instance, settled case) | Ref 7 | Moderate-High (order read) |
| Building a library from pirated copies not excused by training fair use (district court; trial ordered, then settled) | Preliminary | Ref 7 | Moderate-High (order read) |
| Meta won on fair use on the record presented | Preliminary | Ref 8 | Moderate-High (order read) |
| Ross: fair use rejected (non-generative AI), affirmed by Third Circuit | Well Supported (appellate; rehearing/cert. expected) | Ref 6 | Moderate (opinion text not fully read) |
| Model not an "infringing copy" (UK first instance) | Contested (on appeal) | Refs 3, 14 | Moderate-High (judgment read) |
| Memorisation in parameters is reproduction (Munich, first instance) | Contested | Ref 12 | Moderate |
| Generative training lawful generally | Contested | Refs 6-8, 12-13, 18 | Unsettled |
| AI Act copyright policy and summary duties | Established (law in force) | Ref 4 | High (Official Journal text read) |
| UK Government no longer prefers a TDM exception with opt-out (March 2026) | Established (official report) | Ref 17 | High |

## 13. Revision History
- **v0.1.0** (2026-10-15): Initial draft. Citations checked against arXiv/Crossref/publisher pages where marked; not independently fact-checked. Legal summaries rely on secondary sources where marked; no primary judgment text other than the judiciary.uk case page was read.
- **v0.2.0** (2026-10-18): Fact-check audit (docs/audits/SAFE-IP-001_audit.md). Corrected the Third Circuit *Ross* date and status (no longer "sealed"), the *Bartz* approving judge and holding wording, the *Kneschke* legal basis and next-instance status, the *Getty* outcome (trade mark findings added); resolved the Copyright Office Part 2 marker; added UK Government report, *Like Company* and NYT summary-judgment status.