As a substitute, Meta argued, obtainable proof “is plainly indicative” that the flagged grownup content material was torrented for “personal private use”—for the reason that small quantity linked to Meta IP addressess and staff represented solely “a number of dozen titles per 12 months intermittently obtained one file at a time.”
“The way more believable inference to be drawn from such meager, uncoordinated exercise is that disparate people downloaded grownup movies for private use,” Meta's submitting mentioned.
For instance, not like lawsuits raised by e-book authors whose works are a part of an unlimited dataset used to coach AI, the exercise on Meta's company IP addresses solely amounted to about 22 downloads per 12 months. That's nowhere close to the “concerted effort to gather the large datasets Plaintiffs allege are essential for efficient AI coaching,” Meta argued.
Additional, that alleged exercise can't even reliably be linked to any Meta worker, Meta argued.
Strike 3 “doesn't determine any of the people who supposedly used these Meta IP addresses, allege that any had been employed by Meta or had any function in AI coaching at Meta, or specify whether or not (and which) content material allegedly downloaded was used to coach any explicit Meta mannequin,” Meta wrote.
In the meantime, “tens of 1000's of staff,” in addition to “innumerable contractors, guests, and third events entry the Web at Meta daily,” Meta argued. So whereas it's “potential a number of Meta staff” downloaded Strike 3's content material during the last seven years, “it's simply as potential” {that a} “visitor, or freeloader,” or “contractor, or vendor, or restore particular person—or any mixture of such individuals—was liable for that exercise,” Meta instructed.
Different alleged exercise included a declare {that a} Meta contractor was directed to obtain grownup content material at his father's home, however these downloads, too, “are plainly indicative of non-public consumption,” Meta argued. That contractor labored as an “automation engineer,” Meta famous, with no obvious foundation supplied for why he can be anticipated to supply AI coaching information in that function. “No details plausibly” tie “Meta to these downloads,” Meta claimed.
