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Case Tracker: Artificial Intelligence, Copyrights and Class Actions

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Three plaintiff groups, fiction and nonfiction authors, each filed a complaint in the Northern District of California against OpenAI, alleging copyright infringement, vicarious copyright infringement, DMCA violations and torts related to OpenAI’s GPT models and ChatGPT service. These cases — Tremblay v. OpenAI, Silverman v. OpenAI, and Chabon v. OpenAI — are now consolidated here.

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Settlement Conference is scheduled for September 13, 2024.&nbsp;

Case Background

In re: OpenAI ChatGPT Litigation, Master File No. 3:23-cv-3223

Tremblay v. OpenAI, Inc., No. 3:23-cv-03223

Silverman v. OpenAI, Inc., No. 3:23-cv-03416

Chabon v. OpenAI, Inc., No. 3:23-cv-04625

Court: Northern District of California

Judge: District Judge Araceli Martinez-Olguin

Plaintiffs – Paul Tremblay, Sarah Silverman, Christopher Golden, and Richard Kadrey on behalf of themselves and a putative class, represented by Joseph Saveri Law Firm, LLP and Matthew Butterick; Michael Chabon, Ta-Nehisi Coates, Junot Díaz, Andrew Sean Greer, David Henry Hwang, Matthew Klam, Laura Lippman, Rachel Louise Snyder, Ayelet Waldman, and Jacqueline Woodson on behalf of themselves and a putative class, represented by Ventura Hersey &amp; Muller, LLP and Caferty Clobes Meriwether &amp; Sprengel LLP

“OpenAI” – OpenAI, Inc.; OpenAI, L.P.; OpenAI OpCo, L.L.C; OpenAI GP, L.L.C.; OpenAI Startup Fund GP I, L.L.C.; OpenAI Startup Fund I, L.P.; and OpenAI Startup Fund Management, LLC, represented by Morrison &amp; Foerster LLP and Latham &amp; Watkins LLP

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Status Updates

Sept. 3, 2024 – Settlement conference scheduled for September 13, 2024, is vacated.

The court vacated the settlement conference scheduled for September 13, 2024. 

July 30, 2024 – The court granted OpenAI’s motion to dismiss Count II (Unfair Competition Law claim) of the consolidated amended complaint

The court granted OpenAI’s motion to dismiss plaintiff’s Unfair Competition Law claim (Count II) with prejudice.&nbsp;&nbsp;

The court concluded that plaintiffs failed to respond to defendants’ arguments about the “unlawful” or “fraudulent” prongs and thus conceded those theories. In response to plaintiffs’ argument that defendants’ motion was procedurally improper under Rule 12(g), the Court held that Rule 12(g) does not bar consideration of defendants’ preemption argument, and that the Copyright Act preempted the claim at issue because it fell within the subject matter and was qualitatively the same as the direct copyright infringement claim. It explained, “The basis of both claims is the unauthorized copying and use of the Infringed Works to train ChatGPT,” so “[e]ven though the elements of the UCL claim are not identical to the copyright claim, ‘the underlying nature’ of Plaintiffs’ UCL claim is ‘part and parcel of [the] copyright claim.’”

July 12, 2024 – OpenAI filed statement of recent decision

OpenAI filed a statement of recent decision to inform the court of a recent ruling in <a href="https://www.bakerlaw.com/the-copilot-litigation/" target="_blank" rel="noreferrer noopener">Doe v. GitHub, Inc.</a>, which it argued was relevant to its pending motion to dismiss. OpenAI pointed out that the court held that F.R.C.P. Rule 12(g)(2) did not foreclose OpenAI’s arguments that plaintiffs failed to state a breach of contract claim. In Doe, the N.D. California Court concluded that “[d]enying late-filed Rule 12(b)(6) motions . . . can produce unnecessary and costly delays, contrary to the direction of Rule 1” and thus “consider[ed] OpenAI’s arguments” in order to “materially expedite[] the district court’s disposition of the case.” Dkt. 253, at 7.

April 17, 2024 – OpenAI replied to their motion to dismiss

OpenAI filed a [127] reply in support of their [122] motion to dismiss, responding to arguments in plaintiffs’ [126] opposition. OpenAI argued defendants had no reason to raise preemption earlier in the case and Rule 12(g) does not preclude considering OpenAI’s preemption defense. OpenAI maintained that plaintiffs’ unfair competition law claim is preempted and argued that the court’s dismissal should be with prejudice.&nbsp;&nbsp;

OpenAI argued that the court expressly noted an unfair competition claim may be preempted by the Copyright Act, and plaintiffs failed to provide any legitimate argument against preemption to prove otherwise. Additionally, in response to plaintiffs’ argument that OpenAI should have raised the defense sooner, OpenAI claimed that plaintiffs amended their complaint to raise a new claim under the unfair competition law’s “unfair business practices” prong, which prompted this motion to dismiss. There was no argument for preemption prior.

April 10, 2024 – Plaintiffs filed opposition to OpenAI’s motion to dismiss

Plaintiffs filed a [126] response to [122] OpenAI’s motion to dismiss, arguing that the Copyright Act does not preempt plaintiffs’ California unfair competition law claim because that claim is based on theories of unfair competition that do not fall under the subject matter of the Copyright Act. Plaintiffs argued their claim does not stem solely from defendants’ use of their copyrighted works to train and create generative AI models, but that their claim stems from the models’ distortion of the marketplace in which “creators of written work” generally compete. Plaintiffs classified California’s unfair competition laws to reflect the legislature’s intent to eliminate unfair advantages in the marketplace that are detrimental to both consumers and law-abiding competitors, such that the law would protect against OpenAI’s use of the copyrighted work.&nbsp;&nbsp;

Plaintiffs also argued that under F.R.C.P. 12(g)(2), defendants missed their opportunity to raise their preemption argument, arguing defendants “could have raised” their preemption argument when they challenged the initial complaint, and the court should not permit defendants to raise this new objection.&nbsp;&nbsp;

Plaintiffs asked the court to deny defendants’ motion to dismiss or alternatively, grant plaintiffs leave to amend in response to defendants’ new argument.

March 27, 2024 – OpenAI filed motion to dismiss first consolidated amended complaint

OpenAI moved to dismiss plaintiffs’ unfair competition claim with prejudice, on the basis that 17 U.S.C. § 301 expressly preempts it. OpenAI requested for the court to dismiss the claim with prejudice, as the plaintiffs had previously been granted leave to amend and failed in their amended complaint to add the requisite particularity to its claim. OpenAI argued that plaintiffs’ amended complaint does not state an unfair competition claim, as the plaintiffs fail to allege the “unlawful” element and the “fraudulent” element necessary to support its cause of action. Additionally, OpenAI argued that plaintiffs’ claim for “unfair business practices” under the unfair competition law is preempted by the Copyright Act, “as this Court previewed.”

March 13, 2024 – Plaintiffs filed amended complaint against all defendants

Plaintiffs filed a consolidated complaint against OpenAI, alleging two causes of action:

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Feb. 29, 2024 – Tremblay filed reply in support of their motion to intervene

Tremblay plaintiffs responded to defendants’ oppositions to the motion to intervene, stating that defendants only addressed some aspects of the motion but glossed over the main substance, which is the application of the first-to-file rule to these facts. Tremblay plaintiffs argued that it was the extraordinary nature of the defendants’ strategic maneuvering that led them to file the motion to intervene. Defendants initially represented to the SDNY court that they themselves would file a motion to dismiss, stay or transfer the actions under the first-to-file rule, but defendants did not obtain the case schedule they desired so they abstained from filing that motion. OpenAI argued that defendants do not and could not take the new position now that the first-to-file rule does not apply because they had previously taken the opposite position, such that the first-to-file rule should apply and the court should rule accordingly.

Feb. 22, 2024 – OpenAI filed opposition to Tremblay motion to intervene

OpenAI filed opposition to the [98] motion to intervene, arguing that the requested injunction is both inappropriate and unprecedented. OpenAI argued that Tremblay plaintiffs seek to enjoin OpenAI from defending itself but do not intend to prevent the SDNY plaintiffs from continuing to prosecute their claims. OpenAI stated that Tremblay plaintiffs did not cite a single case in which a district court has enjoined a defendant in a separate court from defending itself against a plaintiff’s claims, nor did they present a reason why it was improper for OpenAI to enter into a four-way stipulation with plaintiffs and its co-defendant Microsoft to litigate summary judgment in the SDNY actions. OpenAI requested that the Court deny Tremblay plaintiffs’ motion to intervene.

Feb. 12, 2024 – The court granted in part and denied in part OpenAI’s motions to dismiss

The court granted defendants’ motions to dismiss with leave to amend plaintiffs’ claims for vicarious copyright infringement, violation of the DMCA, negligence, and unjust enrichment. The court denied the motions to dismiss plaintiffs’ Unfair Competition Law (UCL) claim under the “unfair” prong.&nbsp;

In dismissing the vicarious copyright infringement claim with leave to amend, the court determined that plaintiffs’ allegation that “every output of the OpenAI Language Models is an infringing derivative work” was insufficient. In the forthcoming amended complaint, the court required that plaintiffs explain what the outputs entail or allege that any particular output is substantially similar – or similar at all – to their books.&nbsp;

Feb. 8, 2024 – Tremblay filed motion to intervene in S.D.N.Y cases

Intervenors Tremblay, Silverman, Kadrey, and Chabon, among others, filed motion to intervene and asked the Southern District of New York to apply the first-to-file rule and dismiss, or in the alternative, stay or transfer <a href="https://www.bakerlaw.com/alter-v-openai/">Authors Guild, Alter, Basbanes cases</a>, as well as <a href="https://www.bakerlaw.com/new-york-times-v-microsoft/">New York Times</a>. Intervenors fear that OpenAI “is creating the likelihood—or certainty—of inconsistent rulings in overlapping class actions and the attendant waste of judicial resources.” Intervenors argued that the court should permit intervention as a matter of right, pursuant to FRCP § 24(a)(2). If not, they argued that the court should permit permissive intervention for the fact that the actions involve substantially similar defendants, the same putative nationwide class, the same AI technology, and substantially similar claims.&nbsp; Additionally, they argued that the first-to-file rule warrants dismissal of Authors Guild, Alter, New York Times, and Basbanes because intervenors’ actions are competing lawsuits.

Dec. 7, 2023 – Court heard argument on motions to dismiss

Nov. 27, 2023 – OpenAI’s Notice of Kadrey v. Meta Decision

OpenAI notified the court of a recent decision in Kadrey v. Meta Platforms, Inc, dismissing a number of related claims, including claims for vicarious copyright infringement, claims under Section 1202 of the Digital Millennium Copyright Act (DMCA), and claims under California’s Unfair Competition Law.

Nov. 6, 2023 – Court Order Consolidating Cases

The court granted parties’ stipulation to consolidate Tremblay v. OpenAI, Silverman v. OpenAI, and Chabon v. OpenAI for all purposes under Federal Rule of Civil Procedure 42(a). The court ordered plaintiffs to file a consolidated complaint within thirty days of the court’s ruling on Tremblay and Silverman motions to dismiss.

Nov. 6, 2023 – Plaintiffs’ Notice of Hanagami v. Epic Games Decision

Plaintiffs notified the court of a recent Ninth Circuit decision, reversing a district court’s decision to dismiss a copyright infringement claim. The Ninth Circuit stated, “it is generally disfavored for copyright claims to be dismissed for lack of substantial similarity at the pleading stage.”

Oct. 31, 2023 – OpenAI’s Notice of Andersen Decision

OpenAI notified the court of a recent decision in <a href="https://www.bakerlaw.com/andersen-v-stability-ai/" target="_blank" rel="noreferrer noopener">Andersen v. Stability AI,</a> dismissing a number of related claims, including claims for direct and vicarious copyright infringement, claims under Section 1202 of the Digital Millennium Copyright Act (DMCA), and claims under California’s Unfair Competition Law.

Oct. 24, 2023 – Settlement conference set for June 18, 2024

Oct. 11, 2023 – Tremblay and Silverman plaintiffs replied in support of their motion to dismiss

In Tremblay and Silverman, OpenAI filed replies supporting its motions to dismiss Counts 2 through 6 for failure to state a claim. In challenging Count 2 (vicarious infringement), OpenAI argued that “[i]rrespective of how the outcomes came to be, the outcomes themselves are not copyright infringements unless they contain enough protected expression from an original work to be ‘substantially similar’ in the copyright law sense of that phrase.” OpenAI challenged plaintiffs’ Section 1202 claims (Counts 3-4) by pointing to plaintiffs’ exhibits that contradict allegations of CMI removal or OpenAI’s intent. With regard to state law claims (Counts 5-6), OpenAI reiterated its argument that both claims are preempted by the Copyright Act.

Oct. 10, 2023 – Motion to relate Chabon and Tremblay granted

The court granted the motion for administrative relief to relate Chabon v. OpenAI with Tremblay v. OpenAI.

Oct. 5, 2023 – Chabon plaintiffs amended complaint

Chabon plaintiffs amended their complaint to name and include more plaintiffs. The causes of action remain the same.

Sept. 27, 2023 – Tremblay and Silverman plaintiffs filed opposition to defendants’ motion to dismiss

In their opposition, plaintiffs argued that the claims in their complaints were properly pleaded. Plaintiffs “accept[ed] the concession” by defendants in not moving to dismiss direct copyright infringement (Count 1) and argued that OpenAI improperly attempted to “pre-litigate issues” still relevant to the undismissed direct copyright infringement claim. Plaintiffs defended their vicarious infringement claim (Count 2) as proper because the complaint alleged (1) all outputs of OpenAI LLMs are infringing derivative works, (2) OpenAI customers initiated the creation of the infringing outputs, (3) OpenAI has the “right to stop” this customer activity and (4) OpenAI financially benefits from this activity. On the CMI claims (Counts 3-4), plaintiffs argued that they alleged sufficient facts to “support the reasonable inference OpenAI knew that their removal of CMI would aid infringement.” Plaintiffs also argued that their state law claims (Counts 5-6) are not preempted because, for purposes of their state law claims, the rights in question are not the copying of plaintiffs’ works but the unauthorized use of those works as training material for OpenAI’s LLM.

Sept. 20, 2023 – Plaintiffs filed motion to relate Tremblay and Chabon

Plaintiffs filed a motion to relate Chabon v. OpenAI, Inc., No. 3:23-cv-04625 to the Tremblay and Silverman cases.

Sept. 8, 2023 – Chabon plaintiffs filed complaint

Award-winning writers Chabon, Hwang, Klam, Snyder and Waldman filed a putative class action complaint alleging that OpenAI included their books without permission in the training dataset for GPT based on public statements by OpenAI and others regarding the contents of the dataset. The complaint alleged six causes of action:

Direct copyright infringement, alleging that OpenAI made copies of plaintiffs’ works in training LLaMA and that LLaMA is a derivative work of those books because the models “retained” “expressive information” from those books (Count 1)

Vicarious copyright infringement, alleging that every output from LLaMA is a derivative work of the plaintiffs’ books (Count 2)

DMCA § 1202(b) violations for distributing derivative works without copyright management information of the plaintiffs’ books and DMCA § 1202(a) violations for “falsely claiming … sole copyright in the LLaMA models” (Count 3)

Unfair competition, negligence and unjust enrichment (Counts 4-6)

Aug. 28, 2023 – Defendants filed motions to dismiss Tremblay and Silverman

In both cases, OpenAI filed motion to dismiss Counts 2-6 (leaving unchallenged the direct infringement claim against OpenAI) for failure to state a claim under Fed. R. Civ. P. 12(b)(6). In challenging Count 2 (vicarious infringement), OpenAI argued that plaintiffs failed to plead an underlying act of direct infringement, OpenAI’s right and ability to supervise such infringing conduct and OpenAI’s financial interest in such conduct. OpenAI argued that Count 3 failed to plausibly allege CMI removal or OpenAI’s &nbsp;intent, and that Count 4 failed at least because it was premised on defective Count 3. OpenAI argued the final &nbsp;two claims (Counts 5-6) are preempted by the Copyright Act. (Since the Silverman complaint and the Tremblay complaint are nearly identical, it makes sense that OpenAI’s motions to dismiss the claims are also identical.)

Aug. 11, 2023 – Original plaintiff Mona Awad dismissed her claims with prejudice

Awad gave no reasons for dismissing her own claims.

July 28, 2023 – Motion to relate Tremblay and Silverman granted

July 19, 2023 – Plaintiffs proposed relating the Tremblay and Silverman cases

Plaintiffs filed an administrative motion to consider whether the cases should be related.

July 7, 2023 – Silverman plaintiffs filed their complaint

Silverman, Golden and Kadrey filed their complaint contained the same claims as the Tremblay complaint.

June 28, 2023 – Tremblay and Awad filed their complaint

In their putative class action complaint against OpenAI, <a>Tremblay and Awad alleged that OpenAI included plaintiffs’ books without permission in the training dataset for ChatGPT based on</a> the fact that plaintiffs could prompt ChatGPT to generate “accurate summaries” of their books. The complaint alleges six causes of action:

Select Court Documents

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/09/ECF-1-Complaint-3.pdf" target="_blank" rel="noreferrer noopener">June 28, 2023 – ECF 1 Tremblay Complaint</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/09/ECF-1-Complaint-7.7.23.pdf" target="_blank" rel="noreferrer noopener">July 7, 2023 – ECF 1 Silverman Complaint</a> (3:23-cv-3416)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-16-Motion-to-Relate.pdf" target="_blank" rel="noreferrer noopener">July 19, 2023 – ECF 16 Motion to Relate&nbsp;Tremblay&nbsp;and&nbsp;Silverman&nbsp;</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-26-Order-Granting-Silverman-and-Tremblay-Related.pdf" target="_blank" rel="noreferrer noopener">July 28, 2023 – ECF 26 Order Granting [16] Motion to Relate</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/09/ECF-33-OpenAI-Motion-to-Dismiss-8.28.23.pdf" target="_blank" rel="noreferrer noopener">Aug. 28, 2023 – ECF 33 OpenAI Motion to Dismiss Tremblay Complaint</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/09/ECF-32-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">Aug. 28, 2023 – ECF 32 OpenAI Motion to Dismiss Silverman Complaint</a> (3:23-cv-3416)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/09/ECF-1-Chabon-OpenAI-Complaint.pdf" target="_blank" rel="noreferrer noopener">Sept. 8, 2023 – ECF 1 Chabon Complaint</a> (3:23-cv-04625)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/10/48-Tremblay-Opposition.pdf" target="_blank" rel="noreferrer noopener">Sept. 27, 2023 – ECF 48 Tremblay Opposition to Motion to Dismiss</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/10/48-Silverman-Opposition.pdf" target="_blank" rel="noreferrer noopener">Sept. 27, 2023 – ECF 48 Silverman Opposition to Motion to Dismiss</a> (3:23-cv-3416)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-11-Amended-Complaint.pdf" target="_blank" rel="noreferrer noopener">Oct. 5, 2023 – ECF 11 Chabon Amended Complaint&nbsp;</a> (3:23-cv-04625)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/10/54-Tremblay-MTD-Reply.pdf" target="_blank" rel="noreferrer noopener">Oct. 11, 2023 – ECF 54 OpenAI Reply ISO Motion to Dismiss</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2023/10/49-Silverman-MTD-Reply.pdf" target="_blank" rel="noreferrer noopener">Oct. 11, 2023 – ECF 49 OpenAI Reply ISO Motion to Dismiss</a> (3:23-cv-3416)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-59-Settlement-Conference-Order.pdf" target="_blank" rel="noreferrer noopener">Oct. 24, 2023 – ECF 59 Settlement Conference Order</a> (3:23-cv-3416)

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-67-OpenAIs-Notice-of-Andersen-Decision.pdf" target="_blank" rel="noreferrer noopener">Oct. 31, 2023 – ECF 67 OpenAI’s Notice of Andersen Decision</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-69-Plaintiffs-Notice-of-Hanagami-Decision.pdf" target="_blank" rel="noreferrer noopener">Nov. 6, 2023 – ECF 69 Plaintiffs’ Notice of Hanagami Decision</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-74-Order-Consolidating-Cases.pdf" target="_blank" rel="noreferrer noopener">Nov. 7, 2023 – ECF 74 Order Consolidating Cases</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/01/ECF-76-OpenAIs-Notice-of-Kadrey-v.-Meta-Decision.pdf" target="_blank" rel="noreferrer noopener">Nov. 27, 2023 – ECF 76 OpenAI’s Notice of&nbsp;Kadrey v. Meta&nbsp;Decision</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-98-Tremblay-Motion-to-Intervene-in-NY-Cases.pdf" target="_blank" rel="noreferrer noopener">Feb. 8, 2024 – ECF 98 Tremblay Motion to Intervene in NY Cases</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/09/ECF-104-Court-Order-Granting-in-Part-Denying-in-Part-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">Feb. 12, 2024 – ECF 104 Court Order Granting in Part, Denying in Part Motion to Dismiss [33]</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-111-OpenAI-Opposition-to-Tremblay-98-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Feb. 22, 2024 – ECF 111 OpenAI Opposition to Tremblay [98] Motion to Intervene</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-116-Tremblay-Reply-ISO-98-Motion-to-Intervene.pdf" target="_blank" rel="noreferrer noopener">Feb. 29, 2024 – ECF 116 Tremblay Reply ISO [98] Motion to Intervene</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-120-Amended-Complaint.pdf" target="_blank" rel="noreferrer noopener">Mar. 13, 2024 – ECF 120 Amended Complaint</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-122-OpenAI-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">March 27, 2024 – ECF 122 OpenAI Motion to Dismiss</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-126-Opposition-to-122-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">April 10, 2024 – ECF 126 Opposition to [122] Motion to Dismiss</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/04/ECF-127-OpenAI-Reply-to-122-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">April 17, 2024 – ECF 127 OpenAI Reply to [122] Motion to Dismiss</a>&nbsp;

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/07/July-12-2024-–-ECR-158-Statement-of-Recent-Decision.pdf" target="_blank" rel="noreferrer noopener">July 12, 2024 – ECR 158 Statement of Recent Decision&nbsp;</a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/07/July-15-2024-–-ECF-160-Settlement-Conference-Order.pdf" target="_blank" rel="noreferrer noopener">July 15, 2024 – ECF 160 Settlement Conference Order </a>

<a href="https://admin.bakerlaw.com/wp-content/uploads/2024/09/ECF-162-Court-Order-Granting-122-Motion-to-Dismiss.pdf" target="_blank" rel="noreferrer noopener">July 30, 2024 – ECF 162 Court Order Granting [122] Motion to Dismiss</a>