Plaintiff book authors and publishers continue to file copyright lawsuits against AI companies left and right.
Within the last 24 hours, 2 new copyright suits were filed. Both adopt the Shadow Library Strategy of attempting to treat the AI company’s alleged downloading of copies from Shadow Libraries like Books3 as a separate act of infringement apart from training.
This brings the total of U.S. copyright lawsuits against AI companies to 59 lawsuits.
For more about the Shadow Library Strategy, visit:
Entrepreneur Media v. Meta
Book and magazine publisher Entrepreneur Media filed a complaint against Meta arguing both the Shadow Library Strategy and the theory of market dilution discussed by Judge Chhabria in the Kadrey v. Meta lawsuit, which is currently still proceeding on the torrenting/distribution claim.
The publisher is represented by lawyers from Hueston Hennigan, which also represents UMG Recordings in the lawsuits against Suno and Uncharted Labs (the latter settled). The docket is here.
You can see the Shadow Library Strategy argued in this passage of the Complaint:

Entrepreneur Media alleges 3 claims: (1) Direct infringement based in part on Meta’s use of Shadow Library, (2) Contributory copyright infringement in torrenting or distributing copies to others, and (3) DMCA CMI violation.
Here’s the Direct Infringement Claim, which is based in part on the Shadow Library Strategy:

DOWNLOAD ENTREPRENEUR MEDIA’S COMPLAINT V. META
Alexander v. Salesforce
Book author Tasha Alexander filed a complaint against Salesforce similar to the one she filed against Apple. Both rely on the Shadow Library Strategy and allege only one count of infringement.

Here is Count 1, which is based in part on the Shadow Library Strategy:

This is the 2d lawsuit against Salesforce and has already been subject to a motion to relate the case to Tanzer v. Salesforce, which, when granted, will result in both cases being assigned to Judge Charles Breyer.
Lawyers from the law firm of Cotchett, Pitre & McCarthy LLP represent Alexander in both the Apple and Salesforce lawsuits. The docket is here.
DOWNLOAD ALEXANDER’S COMPLAINT V. SALESFORCE