The complaint

Boone Newsmedia, Inc. v. Microsoft Corporation, No. 3:26-cv-00950-DPJ-LGI (S.D. Miss., Northern Division), was filed October 30, 2026. It is Document 1, a 37-page complaint titled Complaint for Damages. The plaintiff is Boone Newsmedia, Inc. The defendants are Microsoft Corporation; OpenAI, Inc.; OpenAI LP; OpenAI GP, LLC; OpenAI, LLC; OpenAI OpCo, LLC; OpenAI Global, LLC; OAI Corporation, LLC; OpenAI Holdings, LLC; OpenAI Foundation; and OpenAI Group PBC. The complaint refers to the OpenAI entities collectively as OpenAI, and to those entities together with Microsoft as Defendants. It alleges as follows on information and belief. The complaint describes the action as one for preliminary and permanent injunctive relief, copyright infringement under 17 U.S.C. 101 et seq., and a violation of 17 U.S.C. 1202(b). Jurisdiction is pleaded under 17 U.S.C. 501 and 28 U.S.C. 1331 and 1338, and venue under 28 U.S.C. 1400(a) and 1391. Boone demands a jury trial for all claims so triable. The court's case-number stamp on the complaint (3:26-cv-00950-DPJ-LGI) shows the case assigned to District Judge Daniel P. Jordan III and Magistrate Judge LaKeysha Greer Isaac, and the docket shows no reassignment entry. (Compl. caption; p. 2; paras. 1, 8 to 9; jury demand; Docket.)

The parties

The complaint alleges, on information and belief, that Boone is an Alabama corporation headquartered in Selma, Alabama, and that it owns and/or manages dozens of newspapers, along with websites, shopping guides, and magazines, in communities in Alabama, Georgia, Michigan, Minnesota, Mississippi, Virginia, and North Carolina. It alleges, on information and belief, that Microsoft is a Washington corporation with its principal place of business and headquarters in Redmond, Washington, and that Microsoft has invested at least $13 billion in OpenAI Global, LLC, in exchange for which Microsoft will receive 75% of that company's profits until the investment is repaid, after which Microsoft will own a 49% stake in that company. It alleges, on information and belief, that Microsoft has described its relationship with the OpenAI defendants as a "partnership," and that the partnership has included contributing and operating the cloud computing services used to copy Boone's works and train the models. It alleges, upon information and belief, that the partnership has also included substantial technical collaboration on the creation of those models. (Compl. paras. 11, 17, 18.)

The complaint alleges, on information and belief, that OpenAI, Inc. is a Delaware nonprofit corporation with its principal place of business in San Francisco, California, formed in December 2015, and that at least until October 28, 2025, it indirectly owned and controlled the other OpenAI entities. It alleges, on information and belief, that OpenAI LP, OpenAI GP, LLC, OpenAI, LLC, OpenAI OpCo, LLC, OpenAI Global, LLC, and OAI Corporation, LLC are Delaware entities with principal places of business in San Francisco; that OpenAI Holdings, LLC is a Delaware limited liability company; that the OpenAI Foundation is a Delaware foundation with a principal office in San Francisco; and that OpenAI Group PBC is a Delaware public benefit corporation with a principal place of business in San Francisco. It alleges, on information and belief, that Microsoft has a minority stake in OpenAI Global, LLC, and that OpenAI, Inc. has a majority stake indirectly through OpenAI Holdings, LLC and OAI Corporation, LLC. It alleges, on information and belief, that on or around October 28, 2025, OpenAI announced that the non-profit entity formerly known as OpenAI, Inc. is now the OpenAI Foundation, and that the for-profit business established in 2019 is now a public benefit corporation called OpenAI Group PBC, which the Foundation continues to control. (Compl. paras. 20 to 29.)

The publications

The complaint alleges, on information and belief, that Boone owns tens of thousands of copyrighted articles and is the owner of registered copyrights. It alleges, on information and belief, that Boone publishes on its websites articles that also appear in the print edition, including articles from older print editions, and that the electronic versions are substantially the same as the print versions. It alleges, on information and belief, that Boone owns and operates subsidiary companies, and it lists the following publications operated through those subsidiaries, each identified by its website. (Compl. paras. 2, 12, 131 to 132.)

  • clantonadvertiser.com
  • peachlivingmagazine.com
  • greenvilleadvocate.com
  • lowndessignal.com
  • luvernejournal.com
  • selmatimesjournal.com
  • shelbycountyreporter.com
  • shelbyliving.com
  • hooversmagazine.com
  • mountainbrookmagazine.com
  • vestaviahillsmagazine.com
  • homewoodlife.com
  • leedslivingmagazine.com
  • moodylivingmagazine.com
  • trussvillelivingmag.com
  • troymessenger.com
  • valleytimes-news.com
  • lagrangenews.com
  • argus-press.com
  • albertleatribune.com
  • austindailyherald.com
  • natchezdemocrat.com
  • vicksburgpost.com
  • thecoastlandtimes.com
  • roanoke-chowannewsherald.com
  • gatescountyindex.com
  • thewashingtondailynews.com
  • smithfieldtimes.com
  • suffolknewsherald.com
  • thetidewaternews.com
  • windsorweekly.com

What the complaint alleges

The complaint alleges, on information and belief, that the defendants used automated systems to crawl Boone's websites, including content behind paywalls and other access restrictions, copied the articles onto their own servers without authorization, and stripped copyright management information such as author credits, publication names, copyright notices, and terms of use information. It alleges, on information and belief, that the stripped content was used to train large language models for products including ChatGPT and Microsoft Copilot, that the models "memorized" the material, and that the violations continue. (Compl. paras. 2 to 4.)

On the training sets, the complaint alleges, on information and belief, that the defendants used datasets including filtered versions of Common Crawl, WebText, and WebText2. It alleges, on information and belief, that GPT-2 was developed using WebText, which includes the text of 45 million links and includes works Boone owns, and that an analysis of the Common Crawl dataset points to tens of thousands of Boone's copyrighted articles and tens of millions of tokens of Boone's content in the Common Crawl dataset used to train GPT-3. It alleges, on information and belief, that the defendants have used, and continue to use, WebText, WebText2, Common Crawl, and other training datasets containing Boone's content to train the GPT models. (Compl. paras. 55, 61, 64, 65.)

The complaint alleges, upon information and belief, that OpenAI used the Dragnet and Newspaper content extractors to remove copyright management information, including author, title, copyright notice, and terms of use information, and that OpenAI has continued to use the same or similar methods for later versions, including Common Crawl. It alleges, upon information and belief, that OpenAI used the same or a similar removal process in constructing the Common Crawl dataset used to train later GPT models. It alleges, on information and belief, that retrieval-augmented generation in products such as ChatGPT Search and Deep Research retrieves Boone's current website content and incorporates it, oftentimes verbatim or in close paraphrase, into responses. It alleges, upon information and belief, that Microsoft products, including Copilot (formerly Bing Chat), also return content taken from Boone's websites without necessarily directing the user to the site or including attribution. (Compl. paras. 47 to 48, 75, 96 to 97, 106.)

Claims and relief

  • Count I, copyright infringement in violation of 17 U.S.C. 501, by Boone against the defendants. It alleges, on information and belief, that Microsoft and the OpenAI defendants directly infringed Boone's exclusive rights under 17 U.S.C. 106 by building training datasets containing Boone's works, including by scraping them from Boone's websites and reproducing them from third-party datasets, and by storing, processing, and reproducing those datasets to train the GPT models on Microsoft's supercomputing platform. It alleges, on information and belief, that storing, processing, and reproducing GPT models that memorized Boone's works was a further joint direct infringement. It alleges, on information and belief, that the OpenAI defendants directly infringed by disseminating generative output containing copies and derivatives through the ChatGPT offerings, and that Microsoft did so through Copilot, formerly known as Bing Chat. It alleges, on information and belief, that the conduct was and continues to be willful. (Compl. paras. 133 to 140.)
  • Count II, vicarious copyright infringement, by Boone. It alleges, on information and belief, that Microsoft controlled, directed, and profited from infringement by the OpenAI defendants, including by controlling the supercomputing platform used to store, process, and reproduce the training datasets, the GPT models, and ChatGPT, and by incorporating the models into Copilot, formerly known as Bing Chat. It alleges, on information and belief, that OpenAI, Inc.; OpenAI, GP; OAI Corporation, LLC; OpenAI Holdings, LLC; and Microsoft controlled, directed, and benefitted from infringement by OpenAI LP; OpenAI Global, LLC; OpenAI OpCo, LLC; OpenAI, LLC; and OpenAI Global PBC (as the complaint names them), including reproduction and distribution of Boone's works. It alleges, on information and belief, that OpenAI Global, LLC and OpenAI LP directed, controlled, and benefitted from infringement by OpenAI OpCo, LLC and OpenAI, LLC. It alleges, on information and belief, that OpenAI, Inc.; OpenAI LP; OAI Corporation, LLC; OpenAI Holdings, LLC; OpenAI Global, LLC; and Microsoft are vicariously liable for copyright infringement. (Compl. paras. 145 to 148.)
  • Count III, violation of the Digital Millennium Copyright Act, 17 U.S.C. 1202(b), alleging that OpenAI removed Boone's copyright management information. It alleges, on information and belief, that OpenAI removed that information when building training datasets, when generating synthetic search results, and when generating outputs from the GPT models, and that OpenAI intentionally removed it in violation of 17 U.S.C. 1202(b)(1). It alleges, on information and belief, that the removal was done knowingly and with the intent to induce, enable, facilitate, or conceal infringement, and that OpenAI knew or had reasonable grounds to know that the removal would facilitate infringement. (Compl. paras. 150 to 157.)

The prayer demands judgment against each defendant for statutory damages, including willful infringement damages, compensatory damages, restitution, disgorgement, and any other relief that may be permitted by law or equity; a permanent injunction against the defendants, their agents and employees, and all persons acting in concert or participation with the defendants, from the unlawful, unfair, and infringing conduct alleged; an injunction under 17 U.S.C. 503(b) requiring the defendants to remove all copies of Registered Works from all GPT or other LLM models and training sets; an award of costs, expenses, and attorney's fees as permitted by law; and such other or further relief as the court may deem appropriate, just, and equitable. (Compl. prayer i to v.)

On the docket

The October 30, 2026 complaint entry describes the filing as a complaint for damages with a jury demand, with a civil cover sheet attached, and lists a filing fee of $405.00, receipt number AMSSDC-6221469. The same day, a summons issued, and the docket records that a notice, form AO-121, reporting the filing or determination of an action or appeal regarding a copyright, was mailed to the Register of Copyrights. (Docket, ECF Nos. 1 to 3.)