It’s useful to compare Judge Bibas’s fair use analysis of the purpose of the defendant ROSS’s use of Westlaw’s copyrighted headnotes for legal decisions. Two things are apparent: 1. While Judge Bibas cautioned in 2023 about “over-reading” the Warhol decision, Judge Bibas in 2025 basically has read Warhol to apply in a way that eliminates … Continue reading Judge Bibas Then and Now on fair use in training AI models. Side by side comparison of Judge’s analysis.