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N.D. Cal.Procedural orderFiled May 24, 2024

T. v. OpenAI LP

Judge
Vince Chhabria
Docket
3:23-cv-04557
Court
U.S. District Court · Northern District of California
Pages
2
Motion to DismissCivil ProcedureClass Action
In one sentence

In Marilyn Cousart v. OpenAI LP, Judge Chhabria granted dismissal motions because the complaint was excessively long and unclear, allowing amendment.

Who this affects

The plaintiffs’ first amended complaint was dismissed with leave to amend. The defendants’ motions to dismiss were granted, and the plaintiffs have 21 days to file an amended complaint.

What happened

In Marilyn Cousart, et al. v. OpenAI LP, et al., the defendants asked the court to dismiss the plaintiffs’ first amended complaint. The complaint was nearly 200 pages long and included irrelevant, repetitive, and distracting material, including discussions of political reactions to artificial intelligence and copyright issues not raised as claims.

The court said the complaint did not provide a short and clear statement showing that the plaintiffs were entitled to relief. It granted the defendants’ motions to dismiss, but allowed the plaintiffs to amend their complaint. The plaintiffs’ amended complaint is due in 21 days, and responses are due 21 days after that.

Judge Vince Chhabria warned that a future complaint could be dismissed with prejudice if it continues to focus on broad policy concerns and irrelevant information. He also questioned whether the plaintiffs or their lawyers could adequately represent absent class members if the case proceeds.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
T. v. OpenAI LP · No. 3:23-cv-04557
Judge
Vince Chhabria
Date
May 24, 2024

Background

The plaintiffs filed a first amended complaint that was nearly 200 pages long. The complaint included allegations about how political leaders and European governments had reacted to advances in artificial intelligence, as well as several pages about copyright concerns even though the plaintiffs did not assert a copyright claim. It also included policy arguments and requested broad injunctive relief involving an independent body of thought leaders approving uses of artificial-intelligence products.

Ruling

The defendants moved to dismiss. The court granted the motions under Federal Rule of Civil Procedure 8(a)(2), which requires a complaint to contain a short and plain statement showing that the plaintiffs are entitled to relief. The court explained that excessive length alone usually is not enough for dismissal, but that dismissal is appropriate when a complaint is needlessly long and contains largely irrelevant, distracting, or redundant information.

The court concluded that the complaint’s unnecessary allegations and policy grievances made it nearly impossible to determine whether the plaintiffs had adequately stated legal claims. Because the court could not tell whether the plaintiffs might state a claim after removing the unrelated material, it dismissed the complaint with leave to amend. Any amended complaint is due in 21 days, and responses are due 21 days afterward.

What happens next

The court warned that if an amended complaint continues to emphasize general policy concerns and irrelevant information in a way that prevents a clear presentation of the legal claims, it will be dismissed with prejudice. The court also stated that, even if the plaintiffs plead a claim that passes the initial pleading stage, the way the current complaint was drafted makes it unlikely that the plaintiffs or their counsel can be trusted to adequately and responsibly represent absent class members. The order does not decide whether the plaintiffs’ underlying legal claims are valid.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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