Danielle Bulger Quoted on Biggest Copyright Rulings of 2025, Discussing Generative AI Models and Jury Trials

Danielle said that US District Judge William Alsup’s assessment of Anthropic’s technology as spectacularly transformative in Bartz et al. v. Anthropic PBC is “a really strong statement for a judge to make, especially on summary judgment.”

“I think it gives a lot of hope to technology companies that are looking to use third-party works to train their LLMs,” she said. Taking into account plaintiffs’ works, Danielle added that Judge Alsup likewise made “a strong determination” regarding the storage of pirated materials.

“I think both sides are walking away with something in this decision,” she said.

Danielle also discussed Gregorini v. Apple Inc. et al. and Buck G. Woodall v. The Walt Disney Co. et al, two recent copyright trials in the entertainment industry in which juries made quick determinations concerning infringement on the threshold issue of access, noting “the basics matter.”

“These cases serve as a reminder to plaintiffs that theories of access have to be more than ‘mere speculation or conjecture,’” she said. “And, for defendants, strategic motion practice where works are not strikingly similar—and where facts fail to suggest a reasonable possibility that a defendant viewed a work—could save time and expenses relating to litigation.”

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