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Judge Orders OpenAI to Hand Over Lawyer Communications on Deleted Book Datasets

The privilege waiver centers on OpenAI’s shifting explanations for deleting the Books1 and Books2 datasets.

Overview

  • Magistrate Judge Ona Wang held that OpenAI put its state of mind at issue, waiving attorney–client privilege over communications about the deletions of Books1 and Books2.
  • Her order requires production of materials she reviewed in camera, all written exchanges with in‑house counsel about the reasons for deletion, and previously redacted internal references to LibGen.
  • Plaintiffs allege an employee downloaded titles from LibGen in 2018 and that the datasets—deleted in 2022—held more than 100,000 books allegedly used to train earlier models.
  • OpenAI said it disagrees with the ruling and intends to appeal, and the court did not apply the crime‑fraud exception.
  • The fight sits in a consolidated MDL involving the Authors Guild, prominent authors, and multiple news organizations, with commentators disputing the decision’s reading of Bartz v. Anthropic on fair use.