Kadrey v. Meta Platforms, Inc.

Kadrey v. Meta Platforms, Inc. is a class action by authors, including Richard Kadrey, alleging that Meta unlawfully copied and used copyrighted books, including from datasets like Books3, to train its LLaMA language models, constituting large-scale copyright infringement under the Copyright Act and depriving authors of licensing revenue.

Consolidation History: The litigation evolved through several consolidation phases. The Chabon case joined the litigation in December 2023, with plaintiffs filing a consolidated amended complaint that streamlined their claims to focus solely on direct copyright infringement, dropping previously dismissed claims. In July 2024, the Huckabee case was formally consolidated, bringing author Lysa TerKeurst as an additional named plaintiff whilst Michael Chabon and Ayelet Waldman withdrew from the proceedings. The Farnsworth case was designated as related in October 2024. The consolidated case now includes claims from multiple authors and content creators, including notable figures such as comedian Sarah Silverman (who is concurrently pursuing similar claims against OpenAI), Pulitzer Prize winner Ta-Nehisi Coates, author Christopher Farnsworth, and former Arkansas Governor Mike Huckabee. The litigation challenges Meta''s use of literary works allegedly obtained from unauthorised sources on multiple grounds, including direct copying claims and DMCA violations. Plaintiffs argue that such use constitutes direct copyright infringement rather than permissible fair use. Meta''s defence strategy has focused on two primary arguments: that its use of the copyrighted materials was transformative in nature, and that there was no direct market substitution between the original works and the AI system''s outputs. On 25 and 27 June 2025, U.S. District Judge Vince Chhabria issued partial dismissals of certain claims brought by the consolidated plaintiffs against Meta. The court dismissed the copying claims and DMCA allegations, finding that the plaintiffs "made the wrong arguments" and failed to develop a sufficient record on market harm.

However, the case continues with copyright claims related to Meta''s alleged downloading of pirated books from "shadow libraries." Whilst acknowledging the transformative nature of LLM training, the court noted that market harm remains "the single most important element of fair use”.

This summary is provided for educational and research purposes only and does not constitute legal advice. Allegations described are those made in the filings. Please consult the underlying source documents.