Youngblood v. Meta Platforms, Inc.

The Complaint alleges that Meta engaged in unauthorised acquisition of content creators' YouTube-hosted audiovisual works through scraping, bulk downloading, and other extraction methods to train Meta's "world model" artificial intelligence systems (including V-JEPA and V-JEPA 2). The Complaint contends that YouTube employs technical measures designed to control access to underlying audiovisual files and prevent bulk extraction by automated systems, making content available primarily through controlled streaming pathways and authorised features. At the scale required for modern AI video-model training, the Complaint alleges that obtaining file-level copies necessarily requires bypassing YouTube's technological controls.

The Complaint alleges that Meta did not obtain licences or permissions from Plaintiffs and class members for file-level acquisition and use of their works as AI training inputs. Instead, the Complaint contends that Meta used or relied on circumvention tools and services to defeat YouTube's technological measures at scale. The Complaint identifies that videos from each Plaintiff's YouTube channel appear in the dataset HowTo100M, which Meta allegedly used to train its AI video-learning architecture.

Plaintiff Youngblood operates "The Youngblood's Podcast" channel featuring weekly episodes discussing marriage, parenting, and family relationships. Plaintiff Chmura operates "Let's Go Team," featuring independent travel content without sponsored viewpoints. Plaintiff Rice operates a channel presenting first-person documentarian content covering various topics. The Complaint alleges that Plaintiffs and class members derive value from their works through viewership, advertising, sponsorships, and licensing that depends on controlled distribution and the ability to choose how their works are licensed for downstream uses.

The Complaint asserts one cause of action for violations of the DMCA's anti-circumvention provisions under 17 U.S.C. § 1201(a), which prohibits circumventing technological measures that effectively control access to copyrighted works and trafficking in circumvention technologies and services. Plaintiffs seek injunctive relief, statutory damages, and other remedies authorised by 17 U.S.C. § 1203.