A new peer-reviewed study claims that finetuning GPT-4o, Google's Gemini-2.5-Pro, and DeepSeek-V3.1 allows researchers to extract up to 90% of copyrighted books in near-verbatim form. The findings directly challenge the legal defences that OpenAI and other AI companies have used in dozens of active copyright lawsuits.
The paper, titled 'Alignment Whack-a-Mole: Finetuning Activates Verbatim Recall of Copyrighted Books in Large Language Models,' was submitted to arXiv on 21 March 2026 and revised on 25 March 2026. Its authors are Xinyue Liu, Niloofar Mireshghallah, Jane C. Ginsburg and Tuhin Chakrabarty, researchers whose combined backgrounds span computer science, machine learning and copyright law.
