Zhang v. Google LLC

On September 11, 2025, Judge Eumi K. Lee of the U.S. District Court for the Northern District of California issued a ruling in In re Google Generative AI Copyright Litigation (23-cv-03440), a consolidated class action brought by ten authors and artists against Google and its parent company, Alphabet. Plaintiffs alleged their copyrighted works were used without permission to train AI models including Bard, Gemini, and Imagen.

The Court allowed direct copyright infringement claims to proceed against Google for models plausibly linked to datasets containing plaintiffs’ works (e.g., Infiniset, C4, LAION-400M/5B). The Court also upheld plaintiffs’ request for injunctive relief, finding allegations of market harm and risk of future infringement sufficient.

However, Judge Lee dismissed with prejudice claims related to ten other models, such as Codey, Veo, MedLM, and others, due to a lack of specific factual allegations. The Court also dismissed with prejudice the vicarious liability claim against Alphabet, holding that a parent company cannot be held liable solely based on its corporate relationship with a subsidiary.

Plaintiffs were given 14 days to file a revised complaint limited to conforming edits. Google must file its answer within 21 days thereafter.

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.