By Matthew Hersh, J.D.
Visual artists will have to show substantial similarity as well.
A trio of visual artists who contend that artificial intelligence software companies violated their copyrights by rendering derivatives of those works in computer-generated output images ...
By Matthew Hersh, J.D.
Visual artists will have to show substantial similarity as well.
A trio of visual artists who contend that artificial intelligence software companies violated their copyrights by rendering derivatives of those works in computer-generated output images will have to replead their case in order to better articulate how they believe the output images are substantially similar to protectible portions of their underlying works, the federal court for San Francisco has held. The court, in rejecting a broad-based contention that AI-generated output images are necessarily derivative wherever they contain identifiable copies of portions of underlying original works, also threw out a large chunk of the artists’ remaining claims against the software companies—albeit with leave to replead (Andersen v. Stability AI Ltd., October 30, 2023, Orrick, W.).
The three companies at the center of this lawsuit are Stable Diffusion, DeviantArt, and MidJourney. Each offers a commercial software program that enables users to custom-generate artworks based on underlying images—over five billion, in fact—that were scraped from the internet. The three companies market their products under different names: Stable Diffusion’s product is called DreamStudio, DeviantArt’s is called DreamUp, and MidJourney’s is called the Midjourney Product. However, each company relies on the training set and software provided by Stable Diffusion.
The mid-2022 launch of the Stable Diffusion platform was not welcomed by everyone, especially by visual artists who claimed that their works were incorporated into the training database for the program. Three of those artists—cartoonist and illustrator Sarah Anderson, painter Kelly McKernan, and illustrator and fine artist Karla Ortiz—brought a class action lawsuit against the three software companies. Their lawsuit alleged copyright infringement, violations of the Digital Millennium Copyright Act, violations of the right of publicity, and unfair competition.
The software companies moved to dismiss, leading to this complaint.
Copyright registrations and identification of the allegedly infringed works. The court first dismissed the copyright claims from two of the artists on straightforward grounds: Neither had registered their works with the Copyright Office. For that matter, the remaining artist, Sarah Anderson, had only registered some of her works—so the copyright claim would be narrowed to those works as well.
As to the claims over those remaining works, the software companies attempted to have them dismissed as well for lack of specificity—but that argument would not prevail. The problem here was that the remaining artist with copyright claims had not identified precisely which of her specific works were used in training the Stability Diffusion software. But that would not halt the claim in its track here, the court found. The artist alleged that output pages from her searches showed that some of her registered works were used as training images, and that was enough. “At this juncture,” the court noted, “the plausible inferences are that all of [her] works that were registered as collections and were online were scraped into the training datasets.”
Direct infringement. The court then dismissed—but with leave to replead—the direct infringement allegations against DeviantArt and MidJourney. Stable Diffusion, as the company that allegedly scraped the remaining artist’s images into its training set, plainly was subject to a claim at this juncture (whether the evidence would support it or fair use would preclude it, of course, would be learned later). But the other two companies were accused only of making use of the Stability Diffusion program in their own offerings. Would those claims survive? The court found that they would not.
None of the artists’ theories of direct infringement against the companies withstood the court’s analysis. The artists first argued that by reproducing and distributing the Stable Diffusion program itself, the companies were therefore reproducing “compressed copies of the training images” underlying that program. But it was not clear whether the artists contended that the Stable Diffusion software packaged contained those compressed images themselves or whether the program contained only a set of algorithms capable of rendering those images (or to be more accurate, rendering user-requested images based on those underlying images). And if the claim was the latter, the court noted, it also was not clear whether a copyright infringement claim could be maintained by an allegation that a defendant distributed a set of instructions capable of reproducing a work, rather than the work itself. In any event, the court found, the artists would be required to amend their complaint to clear up the ambiguity.
Nor could the claim against the companies stand based on the doctrine of derivative works. Here the complaint targeted the output, rather than the input, of the software. The artists repeatedly admitted, the court noted, that none of the output images was likely to be a “close match” for any of the individual works at issue in the lawsuit. Rather, the court noted, the artists contended that the output images were necessarily derivative of the underlying images because each copied some portion of those images, even if the output was intermingled with the content of other images as well. The problem for this claim, the court noted, was that it fell short of alleging that any of the resulting images were substantially similar to any protected part of the original—only that they contained some component that was copied. That was a potentially fatal flaw, the court reasoned. Even the cases the artists relied on, the court noted, “appear to recognize that the alleged infringer’s derivative work must still bear some similarity to the original work or contain the protected elements of the original work.” Again, if this claim was to survive, it would have to be repleaded.
Vicarious infringement. The court dismissed this claim with leave to replead for the same reasons. The issue here was whether Stable Diffusion profited from—and failed to exercise its power to prevent—the alleged direct infringement by the other two companies. But because the direct infringement allegation against those two companies would have to be repleaded, the court noted, it was too early to decide whether the vicarious infringement claim would stand. Absent “more clarity and plausible allegations” as to whether the Stable Diffusion contained “compressed” or other forms of copies of the underlying images, the court noted, this claim would fail.
DMCA claims. These claims too were dismissed, albeit with leave once again to replead. The artists alleged that the Stability Diffusion program removed information identifying them as the authors of their works—content management information or CMI, in the language of the statute—when ingesting them. But these allegations were “wholly conclusory,” the court noted. In order to state this claim, the court observed, each artist must “identify the exact type of CMI included in their online works that were online and that they have a good faith belief were scraped into the … datasets used to train Stable Diffusion.” Nothing in the complaint, at least in its present form, reached this level of specificity.
Right of publicity claims. The court, again, dismissed this claim with leave to replead. The artists’ claim, as clarified on briefing, was that the software companies violated their statutory and common law rights by allowing users to request outputs “in the style of their names.” But the problem for the artists, the court noted, was that “nowhere in the Complaint have they provided any facts specific to the three named plaintiffs to plausibly allege that any defendant has used a named plaintiff’s name to advertise, sell, or solicit purchase of DreamStudio, DreamUp or the Midjourney product.” The artists would therefore need to “allege plausible facts in support regarding each defendants’ use of each plaintiffs’ name in connection with advertising specifically and any other commercial interests of defendants.”
Unfair competition. This claim, too, was dismissed with leave to replead. The artists acknowledged that they could not allege a likelihood of confusion between the output images and their own underlying works. However, they clarified in briefing that their claim was based on deception as to the “origin, sponsorship, or approval” of their works. “That theory appears nowhere in the Complaint,” the court noted, “nor are there plausible facts alleged in support of how a user could be deceived that one of the named plaintiffs was the origin of an Output Image, sponsored the Output Image, or approved of the Output Images such that their goodwill was injured or they suffered other specific injury.” The claim, too, would either be repleaded or fail.
Breach of contract. Finally, the breach of contract claim too was dismissed with leave to replead. The artists leveled this claim specifically at DeviantArt. According to the complaint, one of the sources that Stable Diffusion used to populate its database was artwork that the artists had uploaded to DeviantArt according to terms of service entered into with the service. By spinning back those images through its incorporation of the Stable Diffusion software, the complaint alleged, DeviantArt thus violated those terms of service. But Stable Diffusion was not bound by those terms of the service, the court noted, and it was not clear just what terms DeviantArt could have violated merely by offering the Stable Diffusion service to its users. “If plaintiffs attempt to amend this claim,” the court emphasized, “they must identify the exact provisions in the TOS they contend DeviantArt breached and facts in support of breach of each identified provision.”
The Case is No. 3:23-cv-00201-WHO.
Attorneys: Arielle S. Wagner (Lockridge Grindal Nauen, PLLP) for Sarah Andersen. Mark Alan Lemley (Lex Lumina PLLC) for Stability AI Ltd.
Companies: Stability AI Ltd.; DeviantArt, Inc.; Midjourney, Inc.
MainStory: TopStory Copyright PublicityRights TechnologyInternet CaliforniaNews GCNNews
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