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📝 Page Status: Draft — sourced but not yet reviewed

  • Status: draft
  • Sources: 2
  • Relationships: 4
  • Research debt items: 4

Thomson Reuters Enterprise Centre GmbH v. Ross Intelligence Inc.

Summary

Thomson Reuters Enterprise Centre GmbH v. Ross Intelligence Inc., No. 1:20-cv-613-SB (D. Del. Feb. 11, 2025), is a copyright action over Ross’s use of Westlaw headnotes, via LegalEase “Bulk Memos,” to train a competing legal-research search engine. Judge Stephanos Bibas, sitting by designation, granted Thomson Reuters partial summary judgment on direct infringement of specified headnotes and rejected Ross’s fair-use defense, emphasizing that Ross’s tool was not generative AI and competed with Westlaw.

Verified Facts

  • Plaintiffs Thomson Reuters Enterprise Centre GmbH and West Publishing Corp. own Westlaw, including editorial headnotes and the Key Number System.1
  • Ross built a legal-research search engine that uses artificial intelligence. After Thomson Reuters refused a license, Ross obtained roughly 25,000 Bulk Memos from LegalEase, compiled by lawyers using a guide that explained how to create questions using Westlaw headnotes.1
  • In 2023 the court had largely denied summary judgment on infringement and fair use (694 F. Supp. 3d 467). In 2025 it revised that ruling under Rule 54(b).1
  • The February 11, 2025 opinion granted most of Thomson Reuters’s motion for partial summary judgment on direct copyright infringement and related defenses, granted Thomson Reuters’s motion on fair use, and denied Ross’s fair-use and copyright summary-judgment motions.1
  • The court held Ross’s use was commercial and not transformative because it lacked a further purpose or different character from Westlaw’s: Ross used headnotes as AI data to create a legal-research tool to compete with Westlaw.1
  • The court stated it is undisputed that “Ross’s AI is not generative AI (AI that writes new content itself).” When a user enters a legal question, “Ross spits back relevant judicial opinions that have already been written.”1
  • The court distinguished intermediate-copying software cases including Google LLC v. Oracle America, Inc., on the ground that those cases involved copying necessary for competitors to innovate in computer programs, a factor the court found absent here.1
  • Factor two (nature of the work) and factor three (amount) were treated as favoring Ross, but factor four (market effect) and factor one were treated as more important; weighing them, the court granted summary judgment for Thomson Reuters on fair use.1
  • Remaining factual issues on liability for Appendix A headnotes included whether some copyrights had expired or were untimely created, a question left for the jury.1

Historical Context

Ross is an earlier AI-training copyright case that does not involve a chatbot that writes new prose. The court flagged that limitation expressly so later readers would not treat the opinion as a holding about generative models.1 Generative-training decisions such as Bartz v. Anthropic PBC and Kadrey v. Meta Platforms, Inc. therefore address a different product, even though all three apply § 107.

Jurisdiction: District of Delaware. Authority level: district-court summary judgment. Appellate status is research debt.

The opinion is most useful as a contrast case: when an AI system is trained on copyrighted editorial content to power a substitute research product that returns existing opinions, the court found no transformative purpose and serious market harm.1 Companies building generative systems often argue the opposite—that training produces a new tool rather than a substitute database. Ross shows that labeling a product “AI” does not, by itself, establish fair use.

Relationships

  • CASE-THOMSON-REUTERS-V-ROSS cites SRC-THOMSON-REUTERS-V-ROSS-2025.
  • CASE-THOMSON-REUTERS-V-ROSS related_to STAT-USC-107.
  • CASE-THOMSON-REUTERS-V-ROSS related_to TOPIC-AI-COPYRIGHT.
  • CASE-THOMSON-REUTERS-V-ROSS related_to CASE-GOOGLE-V-ORACLE.

Sources

  1. SRC-THOMSON-REUTERS-V-ROSS-2025: Thomson Reuters v. Ross Intelligence (D. Del. Feb. 11, 2025).

Additional sources (not yet cited in footnotes):

Research Debt

  • Record the 2023 opinion (694 F. Supp. 3d 467) as a dedicated source.
  • Verify Third Circuit appeal docket and any later opinion.
  • Add the complaint and Appendix A headnote list if needed for work-by-work claims.
  • Confirm trial or judgment outcome after the February 2025 liability rulings.

Document metadata

  • Decision date: 2025-02-11
  • Last verified: 2026-08-22

  1. SRC-THOMSON-REUTERS-V-ROSS-2025 — Memorandum opinion (Feb. 11, 2025). Primary district-court authority. ↩↩↩↩↩↩↩↩↩↩↩