[HN Gopher] Microsoft want court to toss lawsuit accusing them o...
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       Microsoft want court to toss lawsuit accusing them of abusing open-
       source code
        
       Author : ThaDood
       Score  : 98 points
       Date   : 2023-02-10 14:47 UTC (8 hours ago)
        
 (HTM) web link (www.reuters.com)
 (TXT) w3m dump (www.reuters.com)
        
       | atomicUpdate wrote:
       | Why does the post title omit OpenAI, so it no longer matches the
       | article's title?
       | 
       | > OpenAI, Microsoft want court to toss lawsuit accusing them of
       | abusing open-source code
        
         | Dylan16807 wrote:
         | Character limit.
        
       | croes wrote:
       | Is it still Fair Use if you make money with it?
        
         | pdonis wrote:
         | Not necessarily. For example, you can make money by writing a
         | review of a book that includes quotes from the book; that is
         | considered fair use. But if you make money by publishing a book
         | that consists solely of quotes from other books that others
         | have copyrighted, on the grounds that this assembly of quotes
         | from other books might be useful to future authors, that would
         | _not_ be fair use.
         | 
         | To me, the latter scenario is much closer to what Github is
         | doing with Copilot, which is one of the things the plaintiffs
         | are alleging violates open source licenses.
        
         | [deleted]
        
         | henryfjordan wrote:
         | Making money from the work is one of the factors for Fair Use
         | but it is not an automatic-fail kind of situation. A judge/jury
         | would need to hear the facts and consider all the factors.
         | 
         | Here's a good link explaining the Fair Use test:
         | https://copyright.columbia.edu/basics/fair-use.html
        
           | croes wrote:
           | But it's pretty clear from the start that Copilot is neither
           | criticism, comment, news reporting, teaching, scholarship,
           | nor research which are covered by fair use.
        
             | orra wrote:
             | You're forgetting transformative use. Think about search
             | engines.
        
               | VanTheBrand wrote:
               | Right but a search engine takes in web pages and outputs
               | search. copilot takes in code and outputs code.
        
             | henryfjordan wrote:
             | The law on fair use says "such as" those categories you
             | list but it is not read that you MUST be in one of those
             | categories to enjoy fair-use. In fact, it goes on in the
             | next sentence to say you need to consider the 4 factor test
             | in every case.
             | 
             | > The fair use of a copyrighted work ... for purposes such
             | as criticism, comment, news reporting, teaching (including
             | multiple copies for classroom use), scholarship, or
             | research, is not an infringement of copyright. In
             | determining whether the use made of a work in any
             | particular case is a fair use the factors to be considered
             | shall include ...
             | 
             | https://www.law.cornell.edu/uscode/text/17/107
        
               | croes wrote:
               | Sounds even worse for Copilot
               | 
               | (1)the purpose and character of the use, including
               | whether such use is of a commercial nature or is for
               | nonprofit educational purposes; (2)the nature of the
               | copyrighted work; (3)the amount and substantiality of the
               | portion used in relation to the copyrighted work as a
               | whole; and (4)the effect of the use upon the potential
               | market for or value of the copyrighted work.
               | 
               | It's commercial, they use all of the code to built the
               | model and the original code loses its value because you
               | can get through Copilot. 3 of 4, depending on the
               | original license it's 4 of 4 against fair use
        
               | henryfjordan wrote:
               | Yeah I think it'll be an uphill battle for copilot, but
               | I'm not 100% convinced yet. One factor can weigh so much
               | more heavily than the others that they still have a
               | chance with 3/4 against them.
               | 
               | The original license of the code used to train on doesn't
               | really matter to the fair use question, that only matters
               | once the fair use defense fails and the court has to
               | decide a remedy.
        
               | Dylan16807 wrote:
               | > they use all of the code to built the model
               | 
               | That's not what "portion used" means. If you summarize a
               | book then the portion used is <1%, not the entire book.
               | 
               | > the original code loses its value because you can get
               | through Copilot
               | 
               | That's not even remotely true. You might get a fragment
               | or two but you have to rebuild a program from scratch to
               | replace it.
               | 
               | And as far as "nature of the copyrighted work" it's a
               | completely different beast. It's a programming tool
               | instead of whatever code was fed into it.
               | 
               | Only commerciality is a clear mark against it, and that
               | factor is far from decisive by itself.
        
         | nerdponx wrote:
         | In the USA, yes. For example, the unanimous ruling in Campbell
         | v. Acuff-Rose Music, Inc. determined that parody is fair use,
         | even if the parody is of a commercial nature:
         | 
         | > Held: 2 Live Crew's commercial parody may be a fair use
         | within the meaning of SS 107. Pp. 574-594.
         | 
         | The ruling states explicitly that commercial usage can be a
         | determining factor in determining whether usage is fair or not,
         | but that it does not in and of itself make the use "unfair".
         | 
         | https://supreme.justia.com/cases/federal/us/510/569/
        
         | klyrs wrote:
         | I don't think that question is particularly relevant to the
         | case. A newspaper can publish, for profit, a book review which
         | quotes excerpts. As far as I understand it, the case hinges on
         | the distribution of major portions of copyrighted works and
         | derivatives thereof, in violation of their licenses. Likewise,
         | see Aaron Swartz, sci-hub, etc -- distribution of copyrighted
         | works need not be for profit to be a violation.
        
       | silverwasthere wrote:
       | https://en.m.wikipedia.org/wiki/Licence_laundering
       | 
       | Seems pretty obvious to me but we'll see how it goes in the
       | court.
        
         | [deleted]
        
         | ThaDood wrote:
         | Huh, I always had this concept in my mind but never knew it
         | actually had a phrase with some legal precedent.
        
       | User23 wrote:
       | Breaking news: litigant wants to win lawsuit.
       | 
       | They probably didn't rigorously track the licensing issue, but
       | I'm pretty sure training a LLM is completely acceptable use of
       | source under Freely licensed code. It would be somewhat amusing
       | though if CoPilot is forced to spit out the license for every
       | piece of code used to develop the derivative work, along with
       | copyright notices and whatever else the licenses may require.
        
         | jen20 wrote:
         | As you describe, a perfectly acceptable outcome is that
         | licenses are respected with respect to attribution and where
         | necessary propagation to derived works.
        
           | jimmaswell wrote:
           | Reading a source then writing your own code with the same
           | ideas in mind isn't a derived work and shouldn't need
           | attribution. It will be a crying shame if Copilot output is
           | mired in unwarranted legal trouble with how much of a
           | productivity booster it is.
        
             | velcrovan wrote:
             | When a computer is fed human-developed code and then
             | reproduces it verbatim elsewhere (which copilot has been
             | shown to do) it is called "copying".
        
             | silverwasthere wrote:
             | I thought everyone knew the person that reads the code can
             | only describe it to someone else who writes the new code.
             | Having the same party do it would make it a copy, if the
             | purpose and construction is the same.
             | 
             | At least that's how compaq beat IBM and started all this
             | monkey business.
             | 
             | Granted I could be full of it, I wasn't alive yet.
        
               | davorak wrote:
               | > I thought everyone knew the person that reads the code
               | can only describe it to someone else who writes the new
               | code. Having the same party do it would make it a copy,
               | if the purpose and construction is the same.
               | 
               | The same party can do it and not have it count as a copy,
               | but it could be a copy if the party was not careful. So a
               | company that wants to avoid potentially being sued will
               | not allow one party to do both. So jimmaswell is correct
               | to my understanding but a company may want extra legal
               | armor/padding.
        
             | jen20 wrote:
             | Well that is indeed the legal question to be answered. The
             | post I replied to asserted the derivative nature.
             | 
             | The ability to copyright-launder via an API will lead to
             | some interesting consequences for sure: I wouldn't want to
             | be elastic search or mongodb relying on source-available
             | licensing if it comes about.
        
               | jimmaswell wrote:
               | I think a more appropriate IP model for code is closer to
               | how patents work. The code must be filed and becomes
               | available to/usable by the public after the protection
               | expires.
        
               | jen20 wrote:
               | Maybe that is more appropriate but it is not the reality
               | of today.
        
             | AlexandrB wrote:
             | All intellectual property law is a tradeoff between
             | efficiency and monetizability. It would be a huge
             | productivity booster to copy/paste source code wholesale as
             | well. Or to implement existing patents instead of having to
             | work around them. But then the market for software would
             | look very different than it does today.
             | 
             | If that's the future people want, that's fine - but
             | everyone should play by the same rules.
        
             | joxel wrote:
             | [flagged]
        
               | AlexandrB wrote:
               | And the people who decided to go ahead with implementing
               | it probably need help filing a motion in court. Are you
               | just railing against specialization?
        
               | joxel wrote:
               | Yeah because thinking its ridiculous people who don't
               | know how to open email decide the future of software
               | cases is railing against specialization :/
        
         | candiddevmike wrote:
         | That's the point though, if you recreate the code you need to
         | follow it's license, which typically involves some kind of
         | attribution. Copilot should be forced to spit out a list of all
         | licenses it referenced. That would actually be pretty valuable.
        
           | randombits0 wrote:
           | Hold on, there is a difference between "recreate" and "copy".
           | Copyright only applies to creative expressions. If the code
           | is trivially "recreated", it's not particularly creative.
           | 
           | Copyrighted content can be used without the holder's
           | permission under "Fair Use".
           | 
           | Don't assume all code can be copyrighted. Purely functional
           | expressions are not copyrightable. Code is math.
           | 
           | There's a lot here to unpack.
        
             | [deleted]
        
             | User23 wrote:
             | By the Curry-Howard correspondence no code should be able
             | to be copyrighted since every program is a formal
             | mathematical proof. However judges aren't usually
             | mathematicians with a background in Computing Science so
             | it's of little consequence.
        
               | henryfjordan wrote:
               | No algorithm should be copyright-able but your expression
               | of that algorithm should. Programming language choice,
               | variable names, comments, code-style, etc are all
               | creative expressions which are relatively independent of
               | the underlying math.
        
           | kosievdmerwe wrote:
           | Furthermore, the language model itself is clearly a for
           | profit derivative work and so would be subject to the wants
           | of the original copyright owners and it is clearly a
           | derivative work since without the inputs of the copyrighted
           | code in its training it would be different and likely less
           | effective.
           | 
           | There's a more interesting question about the copyright
           | status of the code it outputs, since the language model is
           | sort of like a compiler, but also not like a compiler since
           | the output is based on other people's copyrighted code.
           | 
           | I feel a lot of people get caught up on the output code and
           | completely ignore the fact that copilot itself is likely a
           | massive copyright violation.
        
             | henryfjordan wrote:
             | It is absolutely not clear that an ML model is a derivative
             | work. It might be for-profit but there's good arguments
             | that it is incredibly transformative, and that each
             | individual work the model is trained on is minimally
             | important to the model (if you trained the model on every
             | other document in the training set except the one being
             | sued over, the model would perform very similarly). These
             | are factors which will weigh against the copyright holder.
        
             | supriyo-biswas wrote:
             | To add on to this discussion, the scale matters too, and
             | this is something many people tend not to factor in.
             | 
             | Copilot breaks the assumptions about the lossy nature of
             | human memorization, so a lawsuit challenging the merits of
             | the activity is at least warranted.
        
         | wonks wrote:
         | Wait, are you saying that there is legal precedent for training
         | an LLM with open source code to generate proprietary code?
        
           | User23 wrote:
           | That depends. Odds are good some GPL code slipped in
           | somewhere, so using the GPL for the whole thing is an option
           | in that case. And sure you can derive proprietary code from
           | GPL code, so long as you don't publish binaries.
        
             | shagie wrote:
             | I would point to the Oracle vs. Google Supreme Court
             | decision.
             | 
             | https://www.cnn.com/2021/04/05/tech/google-oracle-supreme-
             | co...
             | 
             | > Writing for the Court, Breyer said that while it is
             | difficult to apply traditional copyright concepts in the
             | context of software programming, Google copied "only what
             | was needed to allow users to put their accrued talents to
             | work in a new and transformative program."
             | 
             | > A world where Oracle was allowed to enforce a copyright
             | claim, Breyer added, "would risk harm to the public"
             | because it would establish Oracle as a new gatekeeper for
             | software code others wanted to use.
             | 
             | The fair use tests that were used in the SCOTUS case, I
             | believe, would fall on the side of "developers using GPT or
             | Copilot to generate code do not generate substantial parts
             | of the code and are below the amount of work needed to show
             | sufficient creativity in writing it."
             | 
             | The example is
             | https://horstmann.com/unblog/2010-11-15/NodePolicyImpl.html
             | 
             | If that is not a copyright violation and considered to be
             | fair use, then the code generated by GPT or Copilot likely
             | also falls in the the same bucket.
             | 
             | I don't necessarily agree with that, but that's my reading
             | of the tea leaves.
        
         | spookie wrote:
         | I'm not so sure on whether or not it's completely acceptable to
         | train a LLM under GPL, for example. To bring the point home,
         | reverse engineering efforts follow the clean-room design
         | technique. This is done in an effort to not infringe
         | copyrights.
         | 
         | Would love to see this being done on decompiled proprietary
         | code. Training done on it. And released into the wild.
         | 
         | But the amount of data necessary, and computing power to do it
         | might not be available for the common person.
        
       | mapme wrote:
       | Is there a OSS license that specifically precludes its use in
       | LLMs or effectively does so?
        
         | colejohnson66 wrote:
         | The thing about fair use is that there's nothing a license can
         | do to prevent it. After all, that's the whole _point_ of fair
         | use: to say that there's valid reasons to use pieces of IP
         | without regards to their licenses.
         | 
         | So, if the courts find in Microsoft and OpenAI's favor (which
         | remains to be seen despite the many armchair lawyers here),
         | your license would mean jack squat.
        
       | jsnell wrote:
       | Is there anything out of the ordinary here? Doesn't basically
       | every lawsuit have the defendant file a motion to dismiss, based
       | on any halfway plausible reason?
        
         | lostmsu wrote:
         | Perhaps a meta discussion is needed here regarding the
         | potential ability to dismiss a lawsuit in a scenario like this
         | where everyone understands the existence of a legal problem in
         | the need of future guidance.
        
         | TheRealPomax wrote:
         | There is not. This is standard operating procedure. Getting a
         | case thrown saves _so_ much money that it is entirely worth
         | having your legal team try to make it happen before the real
         | work starts.
        
         | klyrs wrote:
         | To those interested in watching the particulars of this case,
         | this is not a surprising development. But the play-by-play is
         | interesting. Sports announcers manage to talk _continuously_
         | during a game, and don 't sit there silently and say "team A
         | won with 20 points to team B's 5 points, what a game" at the
         | very end. Personally, I don't care for the sportsguy blathering
         | about a game nor the end results, and prefer to read about
         | legal shenanigans.
        
         | nimbius wrote:
         | it was a successful strategy for VMWare when approached by a
         | German developer about improper licensing for his open source
         | code. VMWare managed to get the original case tossed on a
         | technicality, as well as the appeal, which bought them enough
         | time to drop the linux code entirely and avoid a discovery
         | where they would most certainly be found in violation.
         | 
         | https://www.zdnet.com/article/linux-developer-abandons-vmwar...
         | 
         | https://www.zdnet.com/article/vmware-sued-for-failure-to-com...
         | 
         | https://en.wikipedia.org/wiki/Vmlinux
        
         | AlbertCory wrote:
         | Not only is the answer "no, the defendant _always_ files a
         | motion to dismiss, " it's a good strategy because it forces the
         | plaintiff to say something on the record.
        
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