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Fair Use and AI Training Data, a Synthesis of US Litigation 2023–2026

Automated ingestion of copyrighted corpora for training generative systems creates a foundational tension between the four-factor fair use defense and creator reproduction rights. United States federal jurisprudence from 2023 to 2026 demonstrates that courts rigorously balance transformative computational utility against synthetic market substitution and licensing displacement. Statutory reform, specialized computational exceptions, and ex ante dataset recordkeeping are increasingly necessary to reconcile proprietary protection with continuous technological innovation.

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Fair Use and AI Training Data, a Synthesis of US Litigation 2023–2026

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First M. Last

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Dr. First Last

City, 2026

Contents

Abstract
Introduction
Statutory Fair Use and the Transformative Ingestion Doctrine
Non-Expressive Computational Use versus Market Substitution
Synthesis of Federal Jurisprudence and Emerging Case Precedents
Judicial Assessments in Author and Media Publisher Actions
Regulatory Implications and Statutory Reform Frameworks
Conclusion
Bibliography

Introduction

The rapid expansion of generative foundation models relies on the unauthorized mass ingestion of expressive content, triggering significant legal challenges under United States copyright law [1]. Federal courts increasingly grapple with whether automated machine learning on protected corpora constitutes non-expressive transformative fair use or structural infringement of proprietary licensing markets [4].

Judicial inconsistency regarding the boundaries of transformative use has introduced profound uncertainty across creative industries and technology sectors [4]. The absence of standardized transparency protocols for training datasets further complicates evidence gathering and judicial determination of market harm [3]. This situation reveals deep structural tensions between conventional author rights and automated computational processes [1].

This synthesis investigates the evolution of four-factor fair use jurisprudence in United States federal litigation from 2023 through 2026 [4]. Through a doctrinal analysis of major federal disputes and regulatory submissions to the United States Copyright Office, this study outlines critical legal thresholds governing model ingestion and statutory adaptation [2][4].

Statutory Fair Use and the Transformative Ingestion Doctrine

The theoretical classification of automated dataset ingestion within United States copyright jurisprudence turns on the interaction between transformative purpose and commercial market harm. Legal scholars diverge substantially on how the four-factor fair use balancing test applies to machine learning models. Lee (2023) conceptualizes model ingestion as an extension of non-expressive intermediate copying, arguing that extracting statistical correlations from expressive works fulfills a transformative computational function distinct from the underlying expressive content. In contrast, the Knowing Machines Research Project (2023) emphasizes that dataset curation involves extensive pipeline reproduction, curation choices, and systemic data extraction that cannot be decoupled from original expressive labor, thereby challenging simplistic classifications of intermediate processing. Adding to this debate, contemporary analyses of generative systems stress that the sheer scale of unauthorized ingestion alters traditional market dynamics (Fair Use of Training Data in Generative Artificial Intelligence, 2025). When downstream outputs compete directly with creators in primary markets, transformative computational utility is weakened under statutory analysis (Copy, Paste, and Generate: Copyright Law and Fair Use in the Age of Artificial Intelligence, 2025). Consequently, theoretical frameworks in US litigation navigate a doctrinal divide: one approach prioritizes technological innovation through broad intermediate copying exemptions, whereas the competing paradigm demands stricter market accountability to protect original expressive works from automated substitution.

References

  1. Fair Use of Training Data in Generative Artificial Intelligence
    Weiyi Xia
    DOI Link
  2. Comment of Professor Edward Lee to Artificial Intelligence Study by The United States Copyright Office
    Edward Lee
    DOI Link
  3. Comments of the Knowing Machines Research Project to the United States Copyright Office on Copyright Law and Artificial Intelligence (AI)
    Melodi Dinçer, Jason Schultz
    DOI Link
  4. Copy, Paste, and Generate: Copyright Law and Fair Use in the Age of Artificial Intelligence
    Andy Benzo
  5. Generative Artificial Intelligence and the Doctrine of Fair Use: A Critical Analysis of Nepal's Copyright Framework
    Eunice Poudel

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