Copyright Office‌ Report on Generative AI⁢ Misses the Mark on Fair Use

​ Updated May 29, 2025

A recent U.S. Copyright Office⁤ report on generative AI training is facing ⁢criticism for ⁣its assessment of fair use. The report,⁣ released‌ amid personnel changes, addresses various aspects of AI ⁤with differing levels of detail. At⁢ issue is whether using copyrighted material to⁤ train generative AI​ constitutes fair use, a point on which the report’s analysis⁣ is considered flawed.

The report’s conclusions‌ could influence ongoing court cases, including Kadrey v.⁢ Meta platforms, where⁤ the report has already ‍been cited. However, the ⁤report’s analysis is not binding and‌ should only be followed if persuasive.

Generative AI systems require extensive training on ‍human-created works. ⁢Obtaining permission from copyright holders for millions of works is challenging, especially for smaller AI companies. Fair use would eliminate⁣ the need for such permission.

The Copyright Office’s analysis is seen as conflating the use of‍ works for training with​ the⁣ use of models to create similar works. It‌ also allegedly misapplies fair use principles and introduces⁢ a novel theory of market harm.

The report’s transformative ⁣use‍ analysis is ⁣also problematic. ‌Highly transformative uses, serving a different purpose than the original work, ​are generally considered fair use.Using copyrighted works to develop new technologies is typically viewed as transformative.

The Copyright Office’s analysis also considers‌ whether works were obtained in “bad faith,” a factor the Supreme court views skeptically in fair use cases. ​Rights holders⁣ do not have the ⁣right to ⁤control fair​ uses.

The⁤ report introduces a “market harm” theory, suggesting courts should‌ consider ‍the overall effects of using ⁣models to produce similar works. This theory is not supported by precedent and relies ⁣on assumptions about⁤ consumer behavior.

Prioritizing licensing ⁣markets over ​user rights could expand the power of⁢ media companies and stifle innovation.​ Fair use ⁢is essential for technological advancement, providing room for innovation from‍ various technologies.

What’s next

The ⁤courts are​ expected to resolve the pivotal issue of fair use by applying existing law to specific uses and ‌AI technologies, potentially setting precedents for generative AI and‍ copyright law.