Lawsuit tracker
Zhang v. Google
Zhang v. Google LLC, No. 5:24-cv-02531 (N.D. Cal.), consolidated into In re Google Generative AI Copyright Litigation
| Plaintiffs | Jingna Zhang, Sarah Andersen, Hope Larson and Jessica Fink, on behalf of a proposed class of visual artists |
|---|---|
| Defendants | Google LLC and Alphabet Inc. |
| Court | U.S. District Court for the Northern District of California, San Jose (Judge Eumi K. Lee) |
| Filed | 2024-04-26 |
| Status | Active |
| Content type | images |
| Last updated | 2026-07-21 |
The claims
Copyright infringement over the training of Google’s Imagen text-to-image model; plaintiffs seek damages and destruction of infringing copies under 17 U.S.C. § 503
What has happened
Four visual artists — photographer Jingna Zhang and cartoonists Sarah Andersen, Hope Larson and Jessica Fink — sued Google in April 2024, alleging Imagen was trained on the LAION-400M dataset, which Google itself had disclosed, and that the dataset contained their registered works. In late 2024 the case was folded into In re Google Generative AI Copyright Litigation together with author Jill Leovy’s suit, and a consolidated amended complaint was filed on December 20, 2024. Google moved to dismiss parts of the consolidated complaint in January 2025, arguing among other things that plaintiffs had not identified the specific works infringed. Judge Eumi K. Lee heard the motion on April 23, 2025, indicated she was inclined to dismiss some claims, and took it under submission. Proceedings continued into 2026, including a February 2026 hearing, and the parties are in discovery.
Key developments
- 2024-04-26 — Filed in N.D. Cal., alleging Imagen was trained on LAION-400M image-text pairs that included the plaintiffs’ registered works.
- 2024-12-20 — Consolidated amended complaint filed in In re Google Generative AI Copyright Litigation, merging the artists’ claims with author Jill Leovy’s case.
- 2025-01-17 — Google moved to dismiss parts of the consolidated complaint, arguing the works at issue were not specifically identified.
- 2025-04-23 — Judge Lee heard the motion, signaled she was inclined to dismiss some copyright claims, and took the matter under submission.
- 2026-02-20 — Further proceedings were held before Judge Lee as the consolidated case continued in discovery.
Why it matters for training data
This is the lead artist case against a hyperscaler’s in-house image model, and it turns on a public dataset citation: Google’s own paper naming LAION-400M did the plaintiffs’ tracing work for them. The lesson for model builders is that dataset disclosures are discoverable admissions, and the lesson for data suppliers is that open web-scraped sets carry the same exposure as proprietary scrapes. The fight over identifying specific infringed works will shape how much proof artists need before discovery opens.
Sources
- Joseph Saveri Law Firm case page
- CourtListener docket
- Ballard Spahr alert on the complaint
- Bloomberg Law on the consolidation
- Report on the April 2025 motion hearing
Deeper analysis
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