Three New Grok Copyright Lawsuits: Does Buying a Book Permit Scanning It for AI Training?

On November 4, 2026, three separate copyright lawsuits were filed in the U.S. District Court for the Northern District of California: one by academic publisher Cognella, Inc.; one by Cambronne, Inc. and four individual authors; and one by Chicken Soup for the Soul, LLC. The defendants are three related SpaceX Super Intelligence entities, formerly named X.AI, that the complaints describe as developing Grok. ^{4 5 6 7}

According to the complaints, the defendants obtained books from unauthorized online “shadow libraries,” bought print books and scanned them for training, uploaded portions of works to others while downloading through BitTorrent, and removed copyright-management information. These are allegations. They are not findings, and the plaintiffs elected to sue individually rather than as a class. ^{4 5 6 7}

Federal law separates the physical object from the copyright in the work it contains. Transferring a book does not, by itself, convey any rights in the copyrighted work. ¹

The copyright owner generally holds the exclusive right to reproduce the work, subject to statutory limitations and exceptions. ²

Consider a simple example. A company buys a hardcover. It owns that copy and may generally keep it, read it, or resell it. The purchase does not itself transfer the author’s reproduction rights. That explains the ownership distinction—not whether every scan or training use is ultimately lawful.

Fair use is a limitation on the copyright owner’s exclusive rights. Courts consider four statutory factors, among other relevant circumstances: ³

The analysis is fact-specific. A commercial purpose does not automatically defeat fair use, and a claimed technological benefit does not automatically establish it. Not every AI training use is categorically lawful or unlawful, and the absence of a license does not, standing alone, resolve the question.

The complaints plead separate theories for different alleged acts: training on copies from unauthorized sources, scanning purchased print books, and distributing works through file sharing. Each may require separate analysis: ^{4 5}

A conclusion about training does not automatically resolve every acquisition, storage, or distribution issue. Allegedly unauthorized downloads and purchased print copies also present different facts, and the plaintiffs’ descriptions of the source material have not been proven.

Copyright-management information can include a work’s title, author information, and copyright notice when conveyed in connection with copies, performances, or displays of the work. Section 1202(b)(1) addresses intentionally removing or altering that information without authority. Intentional removal is not the whole inquiry: civil liability also requires knowledge, or reasonable grounds to know, that the act will induce, enable, facilitate, or conceal infringement. ⁸

The provision is therefore narrower than a rule that missing attribution is illegal. Removal, distributing works knowing information was removed, and newly generated output can present different questions.

Businesses acquiring or using content for AI development may consider documenting:

These are practical review steps, not a guarantee against liability. Authors and publishers may find the same questions useful in evaluating how their works are used. Mahrouyan Law’s Intellectual Property practice and Startups & Transactions practice address related licensing and ownership questions.