Jacqueline Winspear and 59 other authors sue Meta over Llama and Muse training, adding a separate claim for scanning purchased books

What was filed

The complaint is Document 1 in No. 3:26-cv-12100, U.S. District Court for the Northern District of California, filed and dated October 19, 2026. It runs 53 pages, with a 17-page Exhibit A that the complaint describes as a non-exhaustive list of the plaintiffs' registered copyrights. 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 Stris & Maher LLP of Cerritos, California, and Freedman Normand Friedland LLP of New York, New York, with pro hac vice admission for one attorney 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. 77 to 81; pp. 1, 53.)

The plaintiffs are Jacqueline Winspear, Blaise Aguirre, John Bair, Robert Bell, Alexandra Berlina, Goldie Browning, Aaron Bubbico, Jeff Carollo, Christine Carpenito, Josephine Caust, Gene Cogorno, Jessa Crispin, Harvey Deutschendorf, Stephen Diamond, Roger Dooley, John Ebert, Carol Ekarius, Julen Etxabe, Robert Ficociello, Donald Firesmith, Silvia Foti, Eric Gale, Dawn Gilpin, Laura Gompertz, Reyna Grande, Jeannette Graulau, Raymond Greenwell, Daniel Gumbiner, Owen Gutfreund, Andrew Hargreaves, Paul Herman, Gordon Inkeles, Mary Karlin, Dave Kerpen, Joseph Kertes, Philippe Kruchten, Gary Lamberti, Michelle Leder, Elisabeth Lloyd, Jeanne Marecek, Oleksandr Maslov, Rob McEntarffer, Marsha J. Means, Rachel Nuwer, Joshua Patrick, Minxin Pei, Edward Pollack, David Rollins, Bob Rosner, Tony Rothman, Theodore Savas, Todd Shuster, Janet Sorensen, Mark Spragg, Justin Velez-Hagan, Richard Waters, Robert Wettemann, Bettina Williford, David Wolman, and J. Dylan Yates. The complaint describes each as an author and lists the titles each wrote. As pleaded, 53 of them reside in U.S. states and seven reside in Australia, Canada, Germany, and the United Kingdom. (Compl. paras. 1, 17 to 76.)

Why the plaintiffs say they did not sue as a class

The complaint says the plaintiffs elected not to bring a class action because the Copyright Act entitles them to individualized statutory damages determined by a jury, and that they want to keep control of their case rather than be swept into class settlements. It quotes Feltner v. Columbia Pictures Television, Inc., 523 U.S. 340, 353 (1998), for the point that the amount of statutory damages is a question for the jury. (Compl. paras. 14 to 16.)

What the complaint alleges about Llama

The complaint alleges Meta obtained books for training its Llama models from shadow libraries and datasets it names as Books3 (part of The Pile), Library Genesis (LibGen), Z-Library, and Anna's Archive. Relying 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.), it alleges Books3 was used to train Llama 1 through Llama 4, the LibGen Scitech and Fiction datasets were used to train Llama 3 and Llama 4, and a Z-Library dataset obtained by torrenting Anna's Archive was used to train Llama 4. It alleges Meta used torrenting protocols and, in doing so, reuploaded at least some of the material it downloaded to peer-to-peer networks, through leeching or seeding. (Compl. paras. 129 to 136, 142 to 143.)

It alleges that Meta processed the downloaded data and removed and altered text and information including titles, author information, copyright owner information, and copyright notices, and it quotes an answer it says Meta filed in Kadrey v. Meta Platforms, Inc., No. 3:23-cv-3417 (N.D. Cal.), describing a program "designed to remove lines that contain the word 'copyright.'" For each plaintiff, it alleges the works appear in those libraries according to publicly available metadata, and that there is accordingly "a reasonable inference" that Meta downloaded and reproduced them. (Compl. paras. 84, 139 to 141.)

What the complaint alleges about Muse and book scanning

The complaint alleges that beginning in or around mid-2025, Meta acquired physical copies of books in bulk, scanned them, ran the images through optical character recognition, and used the resulting text to train its Muse models, which it says include Muse Spark, introduced in April 2026, and Muse Glimmer, released in August 2026. It alleges Meta referred to the operation internally as "Project Vellum," and that Meta has admitted copyright-related information from the purchased books was not filtered out before training. It alleges, on information and belief, that Meta acquired, scanned, and used physical copies of the plaintiffs' works this way. The complaint argues that owning a physical copy of a book conveys no right to reproduce the work, citing 17 U.S.C. 106(1), 109(a), and 202, and it pleads this scanning as a basis for liability independent of the shadow-library claims. (Compl. paras. 9 to 10, 146 to 155.)

Counts and relief

There are four counts against Meta: (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 the book-scanning operation; (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 of profits; statutory damages; statutory or actual damages under 17 U.S.C. 1203(c); restitution and 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. 160 to 191; pp. 52 to 53.)

The complaint also draws on filings and rulings in other suits against Meta in the same court, including Kadrey v. Meta Platforms, Inc., 788 F. Supp. 3d 1026 (N.D. Cal. 2025), Cambronne Inc. v. Meta Platforms, Inc., No. 3:26-cv-03725-VC, and Entrepreneur Media, LLC v. Meta Platforms, Inc., No. 25-cv-09579-VC. (Compl. paras. 94, 118, 121, 143, 146 and footnotes.)