Paul Levine and 60 other plaintiffs sue Meta over Llama and Muse training in a complaint that tracks Winspear v. Meta, filed the same day by the same counsel

What was filed

The complaint is Document 1 in No. 3:26-cv-12137, U.S. District Court for the Northern District of California, filed and dated October 19, 2026. It runs 53 pages and refers to an Exhibit A that it describes as a non-exhaustive list of the plaintiffs' registered copyrights; the docket lists that exhibit at 18 pages, and it is not publicly available. The only defendant is Meta Platforms, Inc., which the complaint describes as a Delaware corporation with its principal place of business in Menlo Park, California. Counsel are Elizabeth Brannen and Lauren Martin of Stris & Maher LLP of Cerritos, California, and Kyle Roche of Freedman Normand Friedland LLP of New York, New York, whose pro hac vice admission is listed as forthcoming. Jurisdiction is pleaded under 28 U.S.C. 1331 and 1338(a), and venue under 28 U.S.C. 1400(a) and 1391(b)(2). The plaintiffs demand a jury trial under Federal Rule of Civil Procedure 38(b). (Compl. paras. 76 to 80; pp. 1, 52 to 53; Dkt. 1.)

The 61 plaintiffs are Paul Levine, Nittany Valley Productions, Inc., Abraham Acosta, Richard Antaramian, Carl Bauer, Joseph Buenker, Kathleen Cioffi, Angie Cruz, Kyle Cuordileone, Renee DiResta, Adam Dorin, Ric Dragon, Gabriele Galimberti, Charles Givre, Nicole Gonzalez Van Cleve, Mark Goodacre, Mark Goodale, Mitche Graf, Andrew Hagerman, Barry Halliwell, Pete Havel, Kerri Hawkins, Ari Herstand, Leon Higley, Luke Hohmann, Ray Jackendoff, Jason Alan Jankovsky, Marney Keenan, Mark Koltko-Rivera, Raef Lawson, Rob Long, John Lurz, Thomas Lys, Guadalupe Garcia McCall, Shannon McElroy, Marshall Kirk McKusick, Emily Mendenhall, Mike Murphey, Mike Murphey Books, LLC, David Nelson, Petros Nicopolitidis, John Noyes, Michael Oberman, Hans Ochs, Robert Pasnak, Errol Reiss, Sean Richey, Rick Robinson, Ingrid Rojas Contreras, William Francis Shadwick, Joel Simon, G. Keith Still, Rob Tannenbaum, Nick Thieberger, Neil van Niekerk, Kirsten Vernon, Vendela Vida, David Weiss, Erica Weitzman, Liz Wilson, and Romanus Wolter. The complaint describes each of the 59 individuals as an author and lists the titles each wrote. It describes Nittany Valley Productions, Inc. as a California corporation owned and/or controlled by Paul Levine, and Mike Murphey Books, LLC as a Washington entity owned and/or controlled by Mike Murphey, and pleads that each company and its author together own the listed works. As pleaded, 49 of the individuals reside in U.S. states and ten reside in Australia, Brazil, Canada, Colombia, Greece, Italy, Japan, Singapore, Switzerland, and the United Kingdom. (Compl. paras. 1, 17 to 75.)

How it compares with Winspear v. Meta

This complaint and Winspear v. Meta Platforms, Inc., No. 3:26-cv-12100 (N.D. Cal.), were both filed on October 19, 2026, and Winspear has the lower case number. They share the same counsel and signature block, the same four counts, the same prayer for relief, and the same jury demand. Outside the caption, the list of plaintiffs in paragraph 1, and the plaintiff paragraphs, the body text of the two complaints matches, including the rest of the introduction, the explanation that the plaintiffs elected not to sue as a class so that a jury can set individualized statutory damages (citing Feltner v. Columbia Pictures Television, Inc., 523 U.S. 340, 353 (1998)), and every factual allegation about Llama, torrenting, copyright management information, and Project Vellum. Because Winspear's plaintiff section runs one paragraph longer, the paragraph numbers in Levine are one lower from the exhibit paragraph on. (Compl. paras. 1 to 16, 76 to 190; Winspear Compl. paras. 1 to 16, 77 to 191.)

The differences are the parties and their works. Winspear names 60 individual authors; Levine names 59 individual authors and two companies, the only entity plaintiffs in either case. No plaintiff appears in both complaints. Winspear pleads 53 plaintiffs in U.S. states and seven in four other countries; Levine pleads 49 in U.S. states and ten in ten other countries. The Winspear Exhibit A is public and runs 17 pages; the Levine Exhibit A runs 18 pages and is not publicly available. Neither complaint mentions the other. Neither public docket, as last updated on October 20, 2026, shows a notice of related case or an order relating the two actions; the filings on each are the complaint, the report on the filing of a copyright action, and a certificate of interested entities. (Winspear Compl. paras. 17 to 77; Dkts. 1 to 3 in each case.)

What the complaint alleges

As in Winspear, the complaint alleges Meta obtained books for training its Llama models from Books3 (part of The Pile), Library Genesis (LibGen), Z-Library, and Anna's Archive, relying in part on interrogatory responses it says Meta served in Chicken Soup for the Soul, LLC v. Meta Platforms, Inc., No. 3:26-cv-02333-VC (N.D. Cal.), for the datasets used to train Llama 1 through Llama 4. It alleges Meta torrented data from shadow libraries and, in doing so, reuploaded at least some of the material through leeching or seeding, and that Meta removed titles, author and copyright owner information, and copyright notices from the downloaded data. For each plaintiff, it alleges the works appear in one or more of those libraries and that there is accordingly "a reasonable inference" that Meta downloaded them. (Compl. paras. 17 to 75, 83, 128 to 142.)

It alleges that beginning in or around mid-2025 Meta bought physical books in bulk, scanned them, ran the images through optical character recognition, and used the text to train its Muse models, including Muse Spark and Muse Glimmer, in an operation it says Meta internally called "Project Vellum." For each plaintiff, it alleges the works were published in print and commercially available for purchase while that operation ran, and it alleges, on information and belief, that Meta acquired, scanned, and used physical copies of the plaintiffs' works. It pleads the scanning as a basis for liability separate from the shadow-library claims, arguing that owning a physical copy conveys no right to reproduce the work under 17 U.S.C. 106(1), 109(a), and 202. (Compl. paras. 9 to 10, 17 to 75, 145 to 154.)

Counts and relief

The four counts are (I) direct copyright infringement under 17 U.S.C. 501 based on pirated copies from shadow libraries; (II) direct copyright infringement under 17 U.S.C. 501 based on Project Vellum; (III) contributory copyright infringement under 17 U.S.C. 501 based on uploading through torrenting; and (IV) removal of copyright management information under 17 U.S.C. 1202(b)(1). Willfulness is alleged on Counts I and II. The prayer seeks declarations of infringement, willfulness, and a section 1202(b) violation; a permanent injunction; an accounting; statutory damages; statutory or actual damages under 17 U.S.C. 1203(c); restitution, disgorgement, costs, and attorneys' fees under 17 U.S.C. 505 and 1203(b)(4) to (5); and interest. The complaint states no dollar amount. (Compl. paras. 159 to 190; pp. 51 to 52.)

Watch for whether either side asks the court to treat the Levine and Winspear actions as related, and for Meta's response to each complaint.