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Case 1:24-cv-03285 Document 1 Filed 04/30/24 Page 1 of 98

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF NEW YORK

Daily News, LP; Chicago Tribune Company, LLC;


Orlando Sentinel Communications Company, LLC;
Sun-Sentinel Company, LLC; San Jose Mercury- Civil Action No. _24-3285
News, LLC; DP Media Network, LLC; ORB
Publishing, LLC; and Northwest Publications, LLC,
COMPLAINT
Plaintiffs,

v. JURY TRIAL DEMANDED


MICROSOFT CORPORATION, OPENAI, INC.,
OPENAI LP, OPENAI GP, LLC, OPENAI, LLC,
OPENAI OPCO, LLC, OPENAI GLOBAL, LLC,
OAI CORPORATION, LLC, and OPENAI
HOLDINGS, LLC,

Defendants.

Plaintiffs Daily News, LP (the “New York Daily News”); Chicago Tribune Company, LLC,

(the “Chicago Tribune”); Orlando Sentinel Communications Company, LLC (the “Orlando

Sentinel”); Sun-Sentinel Company, LLC (the “Sun-Sentinel”); San Jose Mercury-News, LLC (the

“Mercury News”); DP Media Network, LLC (the “Denver Post”); ORB Publishing, LLC (the

“Orange County Register”); and Northwest Publications, LLC (the “Pioneer Press”) (collectively

the “Publishers”), by their attorneys Rothwell, Figg, Ernst & Manbeck, P.C., for their complaint

against Defendants Microsoft Corporation (“Microsoft”) and OpenAI, Inc.; OpenAI LP; OpenAI

GP, LLC; OpenAI, LLC; OpenAI OpCo, LLC; OpenAI Global, LLC; OAI Corporation, LLC;

OpenAI Holdings, LLC, (collectively “OpenAI” and, with Microsoft, “Defendants”), allege as

follows:

I. NATURE OF THE ACTION

1. This lawsuit arises from Defendants purloining millions of the Publishers’

copyrighted articles without permission and without payment to fuel the commercialization of their

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generative artificial intelligence (“GenAI”) products, including ChatGPT and Copilot. Although

OpenAI purported at one time to be a non-profit organization, its recent $90 billion valuation

underscores how that is no longer the case. ChatGPT, along with Microsoft Copilot (formerly

known as Bing Chat) has also added hundreds of billions of dollars to Microsoft’s market value.

Defendants have created those GenAI products in violation of the law by using important

journalism created by the Publishers’ newspapers without any compensation.

2. To build and operate GenAI products, Defendants use computers. They pay for

those computers. Defendants use specialized chips. They pay for those chips. Defendants use

electricity to operate the computers. They pay for that electricity. Defendants employ programmers

and other technical employees. They pay those programmers and other employees. They build and

operate their GenAI products in expensive and highly sophisticated facilities. They pay for those

facilities.

3. Defendants also need high quality content in order to make their GenAI products

successful. OpenAI’s founder, Sam Altman, conceded in testimony to the House of Lords in the

U.K. that his company could not make commercially viable GAI products without using

copyrighted material:

Because copyright today covers virtually every sort of human


expression—including blog posts, photographs, forum posts, scraps
of software code, and government documents—it would be
impossible to train today’s leading AI models without using
copyrighted materials. Limiting training data to public domain
books and drawings created more than a century ago might
yield an interesting experiment, but would not provide AI
systems that meet the needs of today’s citizens.1

1
OpenAI, House of Lords Communications and Digital Select Committee inquiry: Large language models (Dec. 5,
2023), https://committees.parliament.uk/writtenevidence/126981/pdf.

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4. Despite admitting that they need copyrighted content to produce a commercially

viable GenAI product, Defendants contend that they can fuel the creation and operation of these

products with the Publishers’ content without permission and without paying for the privilege.

They are wrong on both counts, as this lawsuit will prove.

5. In recent years, the biggest threat to local news generally, and local newspapers in

particular, has been the development of the internet and the theft of newspapers’ content and the

consequent siphoning of advertising revenue. The newspapers that survived this historic

transformation in news delivery were able to do so in part because they continued to provide

content that their readers found to be informative, entertaining, and valuable.

6. Microsoft and OpenAI simply take the work product of reporters, journalists,

editorial writers, editors and others who contribute to the work of local newspapers—all without

any regard for the efforts, much less the legal rights, of those who create and publish the news on

which local communities rely. The Publishers are regional and local news organizations that

provide reporting critical for the neighborhoods and communities that form the very foundation of

our great nation. The Publishers’ journalism ensures that government and power are accountable

to the people, that taxpayers get what they pay for, that there is justice for all, and that citizens

receive timely information critical for their daily lives. The Publishers also connect people and

build consensus by keeping their readers informed.

7. The Publishers have spent billions of dollars sending real people to real places to

report on real events in the real world and distribute that reporting in their print newspapers and

on their digital platforms. Yet Defendants are taking the Publishers’ work with impunity and are

using the Publishers’ journalism to create GenAI products that undermine the Publishers’ core

businesses by retransmitting “their content”—in some cases verbatim from the Publishers’

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paywalled websites—to their readers. As if plagiarizing the Publishers’ work were not enough,

Defendants’ products are often subject to “hallucinations” where those products malign the

Publishers’ credibility by falsely attributing inaccurate reporting to the Publishers’ newspapers.

Beyond just profiting from the theft of the Publishers’ content, Defendants are actively tarnishing

the newspapers’ reputations and spreading dangerous disinformation.

8. This issue is not just a business problem for a handful of newspapers or the

newspaper industry at large. It is a critical issue for civic life in America. Indeed, local news is the

bedrock of democracy and its continued existence is put at risk by Defendants’ actions.

9. The late Speaker of the House, Thomas P. “Tip” O’Neill, famously remarked that

all politics is local. That is as true today as when he said it. Presidential primaries begin in Iowa,

New Hampshire, and South Carolina, and their outcomes are often decided in states such as

Florida—where two of the Publishers operate. Congressmen and Senators typically begin their

political careers in local city councils, mayoral offices, and state legislatures. When major national

news outlets, like CNN, MSNBC, and Fox News, need insights into local politics, they frequently

rely on local news reports from the Publishers and others, and often turn to reporters from local

newspapers for on-air commentary. Politics is local, and local news is an integral part of our

national conversation.

10. Of course, politics is a part of life, but not all of it. When residents of a city or town

want to know what is happening in their community, they look to local news outlets for information

on arts and entertainment, sports, weather, and civic events. Who won the local high school or

college game? What’s playing at local theaters? Will the weather be nice this weekend? What will

the latest city council resolutions on taxes, education, and public transportation mean for my

neighborhood? Local news—and specifically local newspapers—provide in one place the

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information that scores of millions of Americans rely on for the trustworthy and up-to-date

information they need to organize and plan their lives. And local news provides much more,

including job availabilities, house and apartment listings, obituaries, and coverage of other topics

that national news, and even some of the largest city papers, choose not to cover.

11. The impact of local newspapers—or, unfortunately for many Americans, the

absence of them—has important social consequences. Northwestern University’s Local News

Initiative explained the impact of the newspaper divide on American life2:

Economically struggling and traditionally underserved


communities—where residents need journalists providing
transparency and oversight of local government and business
decisions—are the ones most likely to lose a news organization and
be overlooked by funders looking to invest in both for-profit and
nonprofit news operations. That loss of local journalism exacerbates
political, cultural and economic divisions between and within
communities.

12. The Publishers are local newspapers serving many of the largest metropolitan areas

of the country (including New York, Chicago, Orlando, and San Jose) as well as smaller cities,

towns and regions (such as Hartford, Connecticut; Allentown, Pennsylvania; and Norfolk,

Virginia). Collectively, the Publishers are working to narrow the news divide, and to fill in the

“news deserts” that have arisen in many states and regions.

13. These surviving newspapers—increasingly a rare breed in America—now face a

new threat: the GenAI products offered by Defendants Microsoft and OpenAI. In their GenAI

products’ formative stages, Microsoft and OpenAI “scrape” the newspapers’ content, copying it

onto their systems. The scraped content becomes part of the raw material on which Microsoft and

2
P.M. Abernathy, The State of Local News: The 2022 Report, Executive Summary, NORTHWESTERN UNIVERSITY
(June 29, 2022), https://localnewsinitiative.northwestern.edu/research/state-of-local-news/2022/report/.

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OpenAI train their GenAI systems. That is, they copy the informative, entertaining, and valuable

content and style that newspapers (including the Publishers’ newspapers) offer their own paying

subscribers. At the end of the process, the Microsoft and OpenAI GenAI systems offer their users

content that is identical to, or a slightly masked version of, the newspapers’ content.

14. Microsoft and OpenAI bizarrely claim they are entitled to copy and use any written

product on which they want to train their GenAI systems. Microsoft and OpenAI also say even

after their systems are trained, they are entitled to copy local newspapers day in and day out, and

store the newspapers’ content on their servers, as source materials for their GenAI products’ output.

They even go so far as to say that their GenAI products are allowed to copy and provide back to

their users verbatim reprints of local news articles, editorials, reviews, and stories that the local

reporters and editors spend their time, resources, and in some cases even their physical safety, to

write and publish. Microsoft and OpenAI have gone so far as to say that, if anyone should be held

liable for the improper use of local newspaper content, it should be the unsuspecting users of

Microsoft’s and OpenAI’s own products.

15. Since the founding of the United States, the Constitution has granted Congress the

authority to “promote the Progress of Science and useful Arts, by securing for limited Times to

Authors and Inventors the exclusive Right to their respective Writings and Discoveries.” Since our

Nation’s founding in 1789, Congress has seen fit to protect a newspaper’s written material, to

prohibit the copying of that material without the newspaper’s permission, and to require that

anyone who uses that material provide compensation to the newspaper. Microsoft and OpenAI are

ardent defenders of these principles when it comes to their own products, using paywalls and

“shrinkwrap” licenses to protect their GenAI systems and the other products they offer. We can be

quite sure that if newspapers throughout the country decided to use pirated copies of Microsoft

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Windows or Word, or OpenAI’s Chat GPT-4, Microsoft and OpenAI would be quick to assert their

rights. Yet when the shoe is on the other foot, Microsoft and OpenAI say that newspaper content

is not entitled to the same protection.

16. Plaintiffs seek no more than what Microsoft and OpenAI claim for themselves:

recognition that newspapers have legal rights in their content, that Microsoft and OpenAI are

legally required to respect those rights, and that Microsoft and OpenAI owe the newspapers

compensation for their unlawful use of protected newspaper content to date. Both Microsoft and

OpenAI are well aware of the value of the newspaper content they have exploited. Microsoft’s

deployment of Copilot (formerly known as Bing Chat), its GenAI tool that uses the Bing search

index, has helped boost its market capitalization by a trillion dollars in the past year alone. OpenAI,

which used to pretend it was a non-profit organization, now has a market capitalization of over

$90 billion. Yet they both continue to deny that they owe anything to even a single newspaper

whose content they have copied, and continue to copy, to build and operate their GenAI products.

17. This lawsuit is not a battle between new technology and old technology. It is not a

battle between a thriving industry and an industry in transition. It is most surely not a battle to

resolve the phalanx of social, political, moral, and economic issues that GenAI raises. This lawsuit

is about how Microsoft and OpenAI are not entitled to use copyrighted newspaper content to build

their new trillion-dollar enterprises, without paying for that content. As this lawsuit will

demonstrate, Defendants must both obtain the Publishers’ consent to use their content and pay fair

value for such use.

II. JURISDICTION AND VENUE

18. The Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a)

because this action arises under the Copyright Act of 1976, 17 U.S.C. § 101, et seq.

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19. Jurisdiction over Microsoft and OpenAI is proper because they have purposely

availed themselves of the privilege of conducting business in New York. A substantial portion of

Microsoft and OpenAI’s widespread infringement and other unlawful conduct alleged herein

occurred in New York, including the distribution and sales of Microsoft and OpenAI’s Generative

Pre-training Transformer (“GPT”)-based products like ChatGPT, ChatGPT Enterprise, Copilot,

Azure OpenAI Service, Microsoft 365 Copilot, and related application programming interface

(API) tools within New York to New York residents. Furthermore, both Microsoft and the OpenAI

Defendants maintain offices and employ personnel in New York who, upon information and belief,

were involved in the creation, maintenance, or monetization of Microsoft and OpenAI’s

widespread infringement and other unlawful conduct alleged herein.

20. Venue is proper under 28 U.S.C. § 1400(a) because Defendants or their agents

reside or may be found in this District, through the infringing and unlawful activities—as well as

Defendants’ sales and monetization of such activity—that occurred in this District. Venue is also

proper under 28 U.S.C. § 1391(b)(2) because a substantial part of the events giving rise to the

Publishers’ claims occurred in this District, including the marketing, sales, and licensing of

Defendants’ GenAI products built on the infringement of the Publishers’ intellectual property

within this District. Upon information and belief, OpenAI has sold subscriptions for ChatGPT Plus

to New York residents, Microsoft has sold subscriptions for Copilot Pro to New York residents,

and both Microsoft and OpenAI enjoy a substantial base of monthly active users of Copilot and

ChatGPT in New York. OpenAI has licensed its GPT models to New York residents and companies

headquartered in New York. For example, last year, OpenAI struck deals to license its GPT models

to the Associated Press (“AP”) and Morgan Stanley, both companies headquartered in New York.

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III. THE PARTIES

21. Plaintiff Daily News, LP (the “New York Daily News”) is a Delaware limited

partnership with offices located in New York. The New York Daily News publishes digital and

print products, including its core news product, The New York Daily News, which is available on

its mobile application, on its website (www.nydailynews.com), and as a printed newspaper. The

New York Daily News owns over 9,000 registered copyrights for its newspaper issues, including

those set forth in Exhibit A (“New York Daily News Works”).

22. Plaintiff Chicago Tribune Company, LLC (the “Chicago Tribune”) is a Delaware

limited liability company with a principal place of business located in Illinois. The Chicago

Tribune publishes digital and print products, including its core news product, The Chicago

Tribune, which is available on its mobile application, on its website (www.chicagotribune.com),

and as a printed newspaper. The Chicago Tribune owns over 16,000 registered copyrights for its

newspaper issues, including those set forth in Exhibit B (“Chicago Tribune Works”).

23. Plaintiff Orlando Sentinel Communications Company, LLC (the “Orlando

Sentinel”) is a Delaware limited liability company with a principal place of business located in

Florida. The Orlando Sentinel publishes digital and print products, including its core news product,

The Orlando Sentinel, which is available on its mobile application, on its website

(www.orlandosentinel.com), and as a printed newspaper. The Orlando Sentinel owns over 7,000

registered copyrights for its newspaper issues, including those set forth in Exhibit C (“Orlando

Sentinel Works”).

24. Plaintiff Sun-Sentinel Company, LLC (the “Sun-Sentinel”) is a Delaware limited

liability company with a principal place of business located in Florida. The Sun-Sentinel publishes

digital and print products, including its core news product, The Sun-Sentinel, which is available

on its mobile application, on its website (www.sun-sentinel.com), and as a printed newspaper. The

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Sun-Sentinel owns over 8,000 registered copyrights for its newspaper issues, including those set

forth in Exhibit D (“Sun-Sentinel Works”).

25. Plaintiff San Jose Mercury-News, LLC (the “Mercury News”) is a California

limited liability company with a principal place of business located in California. The Mercury

News publishes digital and print products, including its core news product, The Mercury News,

which is available on its mobile application, on its website (www.mercurynews.com), and as a

printed newspaper. The Mercury News owns over 10,000 registered copyrights for its newspaper

issues, including those set forth in Exhibit E (“Mercury News Works”).

26. Plaintiff DP Media Network, LLC (the “Denver Post”) is a Delaware limited

liability company with a principal place of business located in Colorado. The Denver Post

publishes digital and print products, including its core news product, The Denver Post, which is

available on its mobile application, on its website (www.denverpost.com), and as a printed

newspaper. The Denver Post owns over 5,000 registered copyrights for its newspaper issues,

including those set forth in Exhibit F (“Denver Post Works”).

27. Plaintiff ORB Publishing, LLC (the “Orange County Register”) is a Delaware

limited liability company with a principal place of business located in California. The Orange

County Register publishes digital and print products, including its core news product, The Orange

County Register, which is available on its mobile application, on its website (www.ocregister.com),

and as a printed newspaper. The Orange County Register owns over 9,000 registered copyrights

for its newspaper issues, including those set forth in Exhibit G (“Orange County Register Works”).

28. Plaintiff Northwest Publications, LLC (the “Pioneer Press”) is a Delaware limited

liability company with a principal place of business located in Minnesota. The Pioneer Press

publishes digital and print products, including its core news product, The Pioneer Press, which is

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available on its mobile application, on its website (www.twincities.com), and as a printed

newspaper. The Pioneer Press owns over 9,000 registered copyrights for its newspaper issues,

including those set forth in Exhibit H (“Pioneer Press Works”).

29. Microsoft Corporation is a Washington corporation with a principal place of

business and headquarters in Redmond, Washington. Microsoft has invested at least $13 billion in

OpenAI Global, LLC in exchange for which Microsoft will receive 75% of that company’s profits

until its investment is repaid, after which Microsoft will own a 49% stake in that company.

30. Microsoft has described its relationship with the OpenAI Defendants as a

“partnership.” This partnership has included contributing and operating the cloud computing

services used to copy the New York Daily News Works, the Chicago Tribune Works, the Denver

Post Works, the Orlando Sentinel Works, the Sun-Sentinel Works, the Mercury News Works, the

Orange County Register Works, and the Pioneer Press Works (collectively the “Publishers’

Works”) and train the OpenAI Defendants’ GenAI models. It has also included, on information

and belief, substantial technical collaboration on the creation of those models. Microsoft possesses

copies of, or obtains preferential access to, the OpenAI Defendants’ latest GenAI models that have

been trained on and embody unauthorized copies of the Publishers’ Works. Microsoft uses these

models to provide infringing content and, at times, misinformation to users of its products and

online services. During a quarterly earnings call in October 2023, Microsoft noted that “more than

18,000 organizations now use Azure OpenAI Service, including new-to-Azure customers.”

31. The OpenAI Defendants consist of a web of interrelated Delaware entities.

32. Defendant OpenAI, Inc. is a Delaware nonprofit corporation with a principal place

of business located at 3180 18th Street, San Francisco, California. OpenAI, Inc. was formed in

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December 2015. OpenAI, Inc. indirectly owns and controls all other OpenAI entities and has been

directly involved in perpetrating the mass infringement and other unlawful conduct alleged here.

33. Defendant OpenAI LP is a Delaware limited partnership with its principal place of

business located at 3180 18th Street, San Francisco, California. OpenAI LP was formed in 2019.

OpenAI LP is a wholly owned subsidiary of OpenAI, Inc. that is operated for profit and is

controlled by OpenAI, Inc. OpenAI LP was directly involved in perpetrating the mass infringement

and commercial exploitation of the Publishers’ Works alleged here.

34. Defendant OpenAI GP, LLC is a Delaware limited liability company with a

principal place of business located at 3180 18th Street, San Francisco, California. OpenAI GP,

LLC is the general partner of OpenAI LP, and it manages and operates the day-to-day business and

affairs of OpenAI LP. OpenAI GP, LLC is wholly owned and controlled by OpenAI, Inc. OpenAI,

Inc. uses OpenAI GP, LLC to control OpenAI LP and OpenAI Global, LLC. OpenAI GP, LLC was

involved in perpetrating the mass infringement and unlawful exploitation of the Publishers’ Works

alleged here through its direction and control of OpenAI LP and OpenAI Global, LLC.

35. Defendant OpenAI, LLC is a Delaware limited liability company with a principal

place of business located at 3180 18th Street, San Francisco, California. OpenAI, LLC was formed

in September 2020. OpenAI, LLC owns, sells, licenses, and monetizes a number of OpenAI’s

offerings, including ChatGPT, ChatGPT Enterprise, and OpenAI’s API tools, all of which were

built on OpenAI’s mass infringement and unlawful exploitation of the Publishers’ Works. Upon

information and belief, OpenAI, LLC is owned and controlled by both OpenAI, Inc. and Microsoft

Corporation, through OpenAI Global, LLC and OpenAI OpCo, LLC.

36. Defendant OpenAI OpCo, LLC is a Delaware limited liability company with a

principal place of business located at 3180 18th Street, San Francisco, California. OpenAI OpCo,

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LLC is a wholly owned subsidiary of OpenAI, Inc. and has facilitated and directed OpenAI’s mass

infringement and unlawful exploitation of the Publishers’ Works through its management and

direction of OpenAI, LLC.

37. Defendant OpenAI Global, LLC is a Delaware limited liability company formed in

December 2022. OpenAI Global, LLC has a principal place of business located at 3180 18th Street,

San Francisco, California. Microsoft Corporation has a minority stake in OpenAI Global, LLC and

OpenAI, Inc. has a majority stake in OpenAI Global, LLC, indirectly through OpenAI Holdings,

LLC and OAI Corporation, LLC. OpenAI Global, LLC was and is involved in unlawful conduct

alleged herein through its ownership, control, and direction of OpenAI, LLC.

38. Defendant OAI Corporation, LLC is a Delaware limited liability company with a

principal place of business located at 3180 18th Street, San Francisco, California. OAI

Corporation, LLC’s sole member is OpenAI Holdings, LLC. OAI Corporation, LLC was and is

involved in the unlawful conduct alleged herein through its ownership, control, and direction of

OpenAI Global, LLC and OpenAI, LLC.

39. Defendant OpenAI Holdings, LLC is a Delaware limited liability company, whose

sole members are OpenAI, Inc. and Aestas, LLC, whose sole member, in turn, is Aestas

Management Company, LLC. Aestas Management Company, LLC is a Delaware shell company

formed for the purpose of executing a $495 million capital raise for OpenAI.

IV. FACTUAL ALLEGATIONS

A. The Publishers

40. Plaintiff Daily News, LP is the publisher of the New York Daily News, which was

the first newspaper in America to publish in the now-familiar tabloid format. Established in 1919,

and originally called the Illustrated Daily News, the Daily News has long been renowned especially

for its award-winning photojournalism, its iconic headlines and front-page visuals, and its in-depth

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coverage of local events, politics, and sports. The Daily News received its most recent Pulitzer

Prize for Public Service in 2017 for (in the words of the Pulitzer organization) its coverage of

“widespread abuse of eviction rules by the police to oust hundreds of people, most of them poor

minorities.” In 2007, the Daily News’ editorial board won the Pulitzer Prize for a series of editorials

highlighting the declining health of the thousands 9/11 first responders. Following the Daily News’

reporting, Congress passed the James Zadroga 9/11 Health and Compensation Act, Pub. L. 111-

347, which established a federal program to monitor the health of 9/11 first responders, and to

provide aid to those responders in need.

41. Plaintiff Chicago Tribune Company, LLC is the publisher of the Chicago Tribune.

Established in 1847, eight years later the Tribune emerged as one of the first and leading voices

for “Free Soil” and the abolition of slavery in the United States. The Tribune was an early promoter

of Abraham Lincoln’s 1860 presidential candidacy, and ardently supported his administration.

Following the Civil War, the Tribune remained a leading voice in the industrial Midwest during

the late 19th and 20th centuries. Its impact on national and international news has been significant.

In 1919, the Tribune was the first to obtain and publish the text of the Treaty of Versailles, which

ended the first world war. On May 1, 1974, the Tribune was the first newspaper to publish a full

transcript of President Richard Nixon’s Oval Office tapes, leading to his resignation in August of

that year. In 1933, the Tribune’s sports editor created the first Major League Baseball all-star game.

The Tribune staff and reporters have won 28 Pulitzer Prizes, including most recently in 2022 (in

the Local Reporting category, for a series on Chicago’s deficient building- and fire-safety code

enforcement); in 2017 (for Feature Photography, depicting a boy and his mother as their lives

moved forward after he survived a shooting); and in 2017 (Public Service, for reporting on harmful

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pharmacy practices, and particularly noting that the reporting led to reforms that prevented future

harm).

42. Plaintiff San Jose Mercury-News, LLC is the publisher of the San Jose Mercury

News. The Mercury News traces its roots to the California Gold Rush and has been covering the

region now known as Silicon Valley under various names since 1851. It is one of the oldest

continuously published newspapers in California. It has also been the local news publisher of

record for Silicon Valley, the heart of U.S. tech innovation. For more than half a century, the

Mercury News has been a leading source of news and information regarding the growth and

development of the high-technology industry and its impact on the U.S. economy. The Mercury

News has received two Pulitzer Prizes: one in 1986 for international reporting for a series of stories

that documented massive transfers of wealth abroad by President Ferdinand Marcos and his

associates and played a role in the Philippine president’s downfall; and one in 1990 for coverage

of the San Francisco earthquake. Consistent with its focus on technology, the Mercury News was

among the first daily newspapers with an online presence, the first daily newspaper to put its entire

content on its website, and the first daily newspaper to use its website to announce breaking news.

43. Plaintiff Orlando Sentinel Communications Company, LLC is the publisher of the

Orlando Sentinel. The Sentinel is the successor to the Orange County Reporter, which issued its

first edition in 1876. Currently, the Orlando Sentinel covers a diverse part of Florida that includes

tourism, construction and development, agriculture, Disney World, and NASA’s Kennedy Space

Center. From 2001 through 2022, the Orlando Sentinel published a weekly Spanish-language

paper, El Sentinel. In addition to chronicling the rapid transformation of central Florida from a

rural agricultural region to a global vacation and space hub, the Orlando Sentinel has received

accolades for its reporting, having won three Pulitzer Prizes. The prizes ranged from investigative

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reporting for chronicling racial profiling and unjust property seizures by a local sheriff’s office

(1993) and two Pulitzers for editorial writing regarding lax growth management (1982) and

predatory lending practices in Florida (2000). More recently, the Orlando Sentinel was named a

Pulitzer finalist in 2017 for its breaking news coverage of the Pulse nightclub massacre. It also

was named a Pulitzer finalist in 2013 in local reporting for a hazing tragedy at Florida A&M

University.

44. Plaintiff Sun-Sentinel Company, LLC is the publisher of the South Florida Sun

Sentinel, a sister newspaper of the Orlando Sentinel that serves southeast Florida. As with the

Orlando Sentinel, the Sun Sentinel has been a newspaper of record for one of the most dynamic,

growing, and diverse regions in the country, Broward and Palm Beach counties, serving a

population of 3.5 million. In 2013, the Sun Sentinel won its first Pulitzer Prize, awarded in the

category of Public Service journalism, for its series regarding reckless conduct by off-duty police.

It won its second Pulitzer Prize in the same category six years later for its coverage of the mass

shooting at Marjory Stoneman Douglas High School. Its 10-month investigation of the Broward

Sheriff’s Office and Broward School District’s actions before, during and after the massacre led to

changes in state law regarding school safety and led to mass resignations and even prosecution of

deputies at the tragic scene. A 2022 investigative series on sex trafficking in South Florida also led

to bipartisan state legislation cracking down on sex traffickers and the hotels that facilitate it. The

newspaper was a Pulitzer Prize finalist in 2006 for its reporting on federal government

mismanagement during and following Hurricane Wilma. Its photojournalists and visuals staff have

won international recognition for their photography and interactive graphics, and the features

writing department has placed in national contests several times for chronicling South Florida life.

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45. Plaintiff DP Media Network, LLC is the publisher of the Denver Post. Called the

Evening Post when it was first published in 1892, the newspaper has been a leading news outlet in

the Rocky Mountain region for over 125 years. Since 2000, the Post has received five Pulitzer

prizes in a range of categories, and for a variety of subjects—a record that underscores the Post’s

significance in a large and diverse region with few major metropolitan areas. The Post received

Pulitzer Prizes in 2000 for Breaking News Reporting (the Post’s coverage of the Columbine High

School Massacre); in 2010 for Feature Photography; in 2011 for Editorial Cartooning; in 2012 for

Feature Photography; and in 2013 for Breaking News Reporting (the Aurora, Colorado shooting).

During the same period, the Post was a Pulitzer Prize finalist twice, in 2007 (Breaking News

Reporting for coverage of the region’s back-to-back blizzards), and in 2015 (Explanatory

Reporting for coverage of Colorado’s marijuana laws).

46. Plaintiff ORB Publishing, LLC is the publisher of the Orange County Register,

which serves the southern region of California centered on Orange and Los Angeles Counties. The

Register has been known throughout its 120-year history for its iconoclastic stances on major

issues, many of which foreshadowed dramatic changes in American political and social attitudes.

In 1942, at the height of World War II, the Register published an editorial opposing the internment

of Japanese citizens on legal and humanitarian grounds. The Register was one of a few newspapers

to oppose the Iraq War from the outset, and it was an early opponent of efforts in California to

prohibit same-sex marriage. The Register has received three Pulitzer Prizes: in 1985 for

photography at the 1984 Olympics in Los Angeles; in 1989 for specialized reporting for coverage

of the military in Southern California; and in 1996 for investigative reporting that uncovered fraud

and unethical activity at a leading research university hospital and prompted key regulatory

reforms. Since 2000, the Register has been a finalist for two Pulitzer Prizes: in 2004 recognizing

17
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three Register reporters for their investigation of care at 26 local hospitals, and for the reporters’

development of a “report card” to help patients make informed decisions; and in 2005 for reporting

on lead-containing candy from Mexico and its effects on children. The Register continues to do

important public-service journalism, including continued coverage of systemic weakness and

fraud in rehab facilities throughout Southern California and ongoing reporting about misconduct

and abuse in Olympic and college sports programs.

47. Plaintiff Northwest Publications, LLC is the publisher of the St. Paul Pioneer Press.

The Pioneer Press is Minnesota’s first newspaper, celebrating its 175th anniversary this year. Its

earliest ancestor was the Minnesota Pioneer, first published in 1849, just two years after Minnesota

was established as a territory and nine years before it became a state. Winner of three Pulitzer

Prizes, the Pioneer Press has been known for investigative and local enterprise work, for its

commitment to distinct local news and to St. Paul and area communities. Based in Minnesota’s

capital, in a highly competitive news market, the Pioneer Press reports on the Twin Cities of St.

Paul and Minneapolis as well as parts of western Wisconsin.

48. The Publishers expend significant time and effort investigating and reporting local

stories and rely on ad and subscription revenue to further this enterprise. Defendants’ actions

threaten the Publishers’ continued efforts to provide American communities with quality, in-depth

local journalism by copying, using, and adapting the Publishers’ Works in connection with GenAI

products without compensation to the Publishers. These actions deprive the Publishers of visits to

their sites, decrease subscription revenue, and deprive the Publishers of licensing revenue.

49. To preserve the vitality of local journalism, the Publishers go to great lengths to

protect their content. They routinely register copyrights in their content and provide copyright

notices in connection with their works. Beyond the protections provided by the exclusive rights of

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reproduction, adaptation, publication, performance, and display under copyright law, the

Publishers use paywalls to protect some of their content and implement terms of service and terms

of use that restrict the use of the content provided on their websites.3

50. The Publishers require that any third party that wishes to use their content obtain a

license to do so. These licensing agreements allow the Publishers to control how third parties

receive and display their content. The Publishers license their content only under narrowly tailored

terms that provide explicit guardrails regarding how and to what extent third parties can use the

licensed content.

51. Even under these licensing agreements, third parties are not permitted to “scrape”

the content from the Publishers’ websites, as Defendants have done without permission. Instead,

the Publishers retain control over how third parties access licensed content by requiring them to

use specific channels to obtain the Publishers’ Works.

B. Defendants’ GenAI Products

1. A Joint Enterprise Based on Mass Copyright Infringement

52. OpenAI was formed in December 2015 as a “non-profit artificial intelligence

research company.” OpenAI started with $1 billion in seed money from its founders, a group of

some of the wealthiest technology entrepreneurs and investors and companies like Amazon Web

Services and InfoSys. This group included Elon Musk, the CEO of Tesla and X Corp. (formerly

known as Twitter); Reid Hoffman, the co-founder of LinkedIn; Sam Altman, the former president

of Y Combinator; and Greg Brockman, the former Chief Technology Officer of Stripe.

3
See Central Terms of Service, TRIBUNE PUBLISHING, https://www.tribpub.com/central-terms-of-service/ (last
visited Apr. 17, 2024); Terms of Use, MEDIANEWS GROUP, https://www.medianewsgroup.com/terms-of-use/ (last
visited Apr. 17, 2024).

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53. Despite accepting very large investments from enormously wealthy companies and

individuals at its founding, OpenAI originally maintained that its research and work would be

entirely unmotivated by profit. In a December 11, 2015, press release, Brockman and co-founder

Ilya Sutskever (now OpenAI’s President and Chief Scientist, respectively) wrote: “Our goal is to

advance digital intelligence in the way that is most likely to benefit humanity as a whole,

unconstrained by a need to generate financial return. Since our research is free from financial

obligations, we can better focus on a positive human impact.”4 In accordance with that mission,

OpenAI promised that its work and intellectual property would be open and available to the public,

that its “[r]esearchers will be strongly encouraged to publish their work, whether as papers, blog

posts, or code” and that its “patents (if any) will be shared with the world.”5

54. Despite its early promises of altruism, OpenAI quickly became a multi-billion

dollar for-profit business built in large part on the unlicensed exploitation of copyrighted works

belonging to Publishers and others. Just three years after its founding, OpenAI shed its exclusively

nonprofit status. It created OpenAI, LP in March 2019, a for-profit company dedicated to

conducting the lion’s share of OpenAI’s operations—including product development—and to

raising capital from investors seeking a return. OpenAI’s corporate structure grew into an intricate

web of for-profit holding, operating, and shell companies that manage OpenAI’s day-to-day

operations and grant OpenAI’s investors (most prominently, Microsoft) authority and influence

over OpenAI’s operations, all while raising billions in capital from investors. The result: OpenAI

today is a commercial enterprise valued as high as $90 billion.

4
Greg Brockman & Ilya Sutskever, Introducing OpenAI, OPENAI (Dec. 11, 2015),
https://openai.com/blog/introducing-openai.
5
Id.

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55. With the transition to for-profit status came another change: OpenAI also ended its

commitment to openness. OpenAI released the first two iterations of its flagship GenAI model,

GPT-1 and GPT-2, on an open-source basis in 2018 and 2019, respectively. But OpenAI changed

course in 2020, starting with the release of GPT-3 shortly after OpenAI LP and other for-profit

OpenAI entities were formed and took control of product design and development.

56. GPT-3.5 and GPT-4 are both orders of magnitude more powerful than the two

previous generations, yet Defendants have kept their design and training entirely a secret. For

previous generations, OpenAI had voluminous reports detailing the contents of the training set,

design, and hardware of the LLMs. Not so for GPT-3.5 or GPT-4. For GPT-4, for example, the

“technical report” that OpenAI released said: “this report contains no further details about the

architecture (including model size), hardware, training compute, dataset construction, training

method, or similar.”6

57. OpenAI’s Chief Scientist Sutskever justified this secrecy on commercial grounds:

“It’s competitive out there …. And there are many companies who want to do the same thing, so

from a competitive side, you can see this as maturation of the field.”7 But its effect was clearly to

conceal the identity of the data OpenAI copied to train its latest models from rightsholders like the

Publishers.

58. OpenAI became a household name upon the release of ChatGPT in November

2022. ChatGPT is a text-generating chatbot that, given user-generated prompts, can mimic

humanlike natural language responses. ChatGPT was an instant viral sensation, reaching one

million users within a month of its release and gaining over 100 million users within three months.

6
OPENAI, GPT-4 TECHNICAL REPORT (2023), https://cdn.openai.com/papers/gpt-4.pdf.
7
James Vincent, OpenAI Co-Founder on Company’s Past Approach to Openly Sharing Research: ‘We Were Wrong’,
THE VERGE (Mar. 15, 2023), https://www.theverge.com/2023/3/15/23640180/openai-gpt-4-launch-closedresearch-
ilya-sutskever-interview.

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59. OpenAI, through OpenAI OpCo, LLC and at the direction of OpenAI, Inc., OpenAI

LP, and other OpenAI entities, offers a suite of services powered by its LLMs, targeted to both

ordinary consumers and businesses. A version of ChatGPT powered by GPT-3.5 is available to

users for free. OpenAI also offers a premium service, powered by OpenAI’s “most capable model”

GPT-4, to consumers for $20 per month. OpenAI’s business-focused offerings include ChatGPT

Enterprise and ChatGPT API tools designed to enable developers to incorporate ChatGPT into

bespoke applications. OpenAI also licenses its technology to corporate clients for licensing fees.

60. These commercial offerings have been immensely valuable for OpenAI. Over 80%

of Fortune 500 companies are using ChatGPT.8 According to recent reports, in December 2023

OpenAI achieved $2 billion in revenue and expects to double this figure to $4 billion in revenue

in 2025.9

61. This commercial success is built in large part on OpenAI’s large-scale copyright

infringement. One of the central features driving the use and sales of ChatGPT and its associated

products is the LLM’s ability to produce natural language text in a variety of styles. To achieve

this result, OpenAI made numerous reproductions of copyrighted works owned by the Publishers

in the course of “training” the LLM.

62. Upon information and belief, all of the OpenAI Defendants have been either

directly involved in or have directed, controlled, and profited from OpenAI’s widespread

infringement and commercial exploitation of the Publishers’ Works. OpenAI, Inc., alongside

Microsoft, controlled and directed the widespread reproduction, distribution, and commercial use

of the Publishers’ Works perpetrated by OpenAI LP and OpenAI Global, LLC, through a series of

8
OpenAI, Introducing ChatGPT Enterprise, OPENAI (Aug. 28, 2023), https://openai.com/blog/introducing-chatgpt-
enterprise.
9
Reuters, OpenAI hits $2 bln revenue milestone – FT, REUTERS (Feb. 9, 2024),
https://www.reuters.com/technology/openai-hits-2-bln-revenue-milestone-ft-2024-02-09/.

22
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holding and shell companies that include OpenAI Holdings, LLC, OpenAI GP, LLC, and OAI

Corporation, LLC., OpenAI LP and OpenAI Global, LLC were directly involved in the design,

development, and commercialization of OpenAI’s GPT-based products, and directly engaged in

the widespread reproduction, distribution, and commercial use of the Publishers’ Works. OpenAI

LP and OpenAI Global, LLC also controlled and directed OpenAI, LLC and OpenAI OpCo, LLC,

which were involved in distributing, selling, and licensing OpenAI’s GPT-based products, and thus

monetized the reproduction, distribution, and commercial use of the Publishers’ Works.

63. Since at least 2019, Microsoft has been, and continues to be, intimately involved in

the training, development, and commercialization of OpenAI’s GPT products. In an interview with

the Wall Street Journal at the 2023 World Economic Forum, Microsoft CEO Satya Nadella said

that the “ChatGPT and GPT family of models … is something that we’ve been partnered with

OpenAI deeply now for multiple years.” Through this partnership, Microsoft has been involved in

the creation and commercialization of GPT LLMs and products based on them in at least two ways.

64. First, Microsoft created and operated bespoke computing systems to execute the

mass copyright infringement detailed herein. These systems were used to create multiple

reproductions of the Publishers’ intellectual property for the purpose of creating the GPT models

that exploit and, in many cases, retain large portions of the copyrightable expression contained in

those works.

65. Microsoft is the sole cloud computing provider for OpenAI. Microsoft and OpenAI

collaborated to design the supercomputing systems powered by Microsoft’s cloud computer

platform Azure, which were used to train all OpenAI’s GPT models after GPT-1. In a July 2023

keynote speech at the Microsoft Inspire conference, Mr. Nadella said: “We built the infrastructure

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to train their models. They’re innovating on the algorithms and the training of these frontier

models.”

66. That infrastructure was not just general purpose computer systems for OpenAI to

use as it saw fit. Microsoft specifically designed it for the purpose of using essentially the whole

internet—curated to disproportionately feature the Publishers’ Works—to train the most capable

LLM in history. In a February 2023 interview, Mr. Nadella said:

But beneath what OpenAI is putting out as large models, remember,


the heavy lifting was done by the [Microsoft] Azure team to build
the computer infrastructure. Because these workloads are so
different than anything that’s come before. So we needed to
completely rethink even the datacenter up to the infrastructure that
first gave us even a shot to build the models. And now we’re
translating the models into products.10

67. Microsoft built this supercomputer “in collaboration with and exclusively for

OpenAI,” and “designed [it] specifically to train that company’s AI models.”11 Even by

supercomputing standards, it was unusually complex. According to Microsoft, it operated as “a

single system with more than 285,000 CPU cores, 10,000 GPUs and 400 gigabits per second of

network connectivity for each GPU server.”12 This system ranked in the top five most powerful

publicly known supercomputing systems in the world.

68. To ensure that the supercomputing system suited OpenAI’s needs, Microsoft

needed to test the system, both independently and in collaboration with OpenAI software

engineers. According to Mr. Nadella, with respect to OpenAI: “They do the foundation models,

and we [Microsoft] do a lot of work around them, including the tooling around responsible AI and

10
First on CNBC: CNBC Transcript: Microsoft CEO Satya Nadella Speaks with CNBC’s Jon Fortt on “Power
Lunch” Today, CNBC (Feb. 7, 2023), https://www.cnbc.com/2023/02/07/first-on-cnbc-cnbc-transcriptmicrosoft-
ceo-satya-nadella-speaks-with-cnbcs-jon-fortt-on-power-lunch-today.html.
11
Jennifer Langston, Microsoft Announces New Supercomputer, Lays Out Vision for Future AI Work, MICROSOFT
(May 19, 2020), https://news.microsoft.com/source/features/ai/openai-azure-supercomputer/.
12
Id.

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AI safety.” Upon information and belief, such “tooling around AI and AI safety” involves the

finetuning and calibration of the GPT-based products before their release to the public.13

69. Second, in collaboration with OpenAI, Microsoft has also commercialized

OpenAI’s GPT-based technology, and combined it with its own Bing search index. In February

2023, Microsoft unveiled Bing Chat (now Copilot), a generative AI chatbot feature on its search

engine powered by GPT-4. In May 2023, Microsoft and OpenAI unveiled “Browse with Bing,” a

plugin to ChatGPT that enabled it to access the latest content on the internet through the Microsoft

Bing search engine. Copilot and Browse with Bing combine GPT-4’s ability to mimic human

expression—including the Publishers’ expression—with the ability to generate natural language

summaries of search result contents, including hits on the Publishers’ Works, that obviate the need

to visit the Publishers’ websites. These “synthetic” search results purport to answer user queries

directly and may include extensive paraphrases and direct quotes of the Publishers’ reporting. Such

copying maintains engagement with Defendants’ own sites and applications instead of referring

users to the Publishers’ websites in the same way as organic listings of search results.

70. In an interview, Mr. Nadella acknowledged Microsoft’s intimate involvement in

OpenAI’s operations and, therefore, its copyright infringement:

[W]e were very confident in our own ability. We have all the IP
rights and all the capability. If OpenAI disappeared tomorrow, I
don’t want any customer of ours to be worried about it quite
honestly, because we have all of the rights to continue the
innovation. Not just to serve the product, but we can go and just do
what we were doing in partnership ourselves. We have the people,
we have the compute, we have the data, we have everything.14

13
SÉBASTIEN BUBECK ET AL., SPARKS OF ARTIFICIAL GENERAL INTELLIGENCE: EARLY EXPERIMENTS WITH GPT-4
(2023), https://arxiv.org/pdf/2303.12712.pdf.
14
Satya Nadella on Hiring the Most Powerful Man in AI When OpenAI threw Sam Altman overboard, Microsoft’s
CEO saw an opportunity, NEW YORK MAGAZINE (Apr. 17, 2024), https://nymag.com/intelligencer/2023/11/on-with-
kara-swisher-satya-nadella-on-hiring-sam-altman.html.

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71. Through their collaboration in both the creation and the commercialization of the

GPT models, Defendants have profited from the massive copyright infringement, commercial

exploitation, and misappropriation of the Publishers’ intellectual property. As Mr. Nadella put it,

“[OpenAI] bet on us, we bet on them.”15 He continued, describing the effect of Microsoft’s $13

billion investment:

And that gives us significant rights as I said. And also this thing, it’s
not hands off, right? We are in there. We are below them, above
them, around them. We do the kernel optimizations, we build tools,
we build the infrastructure. So that’s why I think a lot of the
industrial analysts are saying, ‘Oh wow, it’s really a joint project
between Microsoft and OpenAI.’ The reality is we are, as I said, very
self-sufficient in all of this.16

2. How GenAI Models Work

72. Microsoft and OpenAI created and distributed reproductions of the Publishers’

Works in several independent ways while training their LLMs and operating the products that

incorporate them.

73. Appending the output of an LLM to its input and feeding it back into the model

produces sentences and paragraphs word by word. This is how ChatGPT and Copilot generate

responses to user queries, or “prompts.”

74. LLMs encode the information from the training corpus that they use to make these

predictions as numbers called “parameters.” There are approximately 1.76 trillion parameters in

the GPT-4 LLM.

75. The process of setting the values for an LLM’s parameters is called “training.”

Training involves storing copies of the training articles in computer memory, providing a portion

15
Steven Levy, Microsoft’s Satya Nadella is Betting Everything on AI, WIRED (June 13, 2023),
https://www.wired.com/story/microsofts-satya-nadella-is-betting-everything-on-ai/.
16
Satya Nadella on Hiring the Most Powerful Man in AI When OpenAI threw Sam Altman overboard, Microsoft’s
CEO saw an opportunity, supra n. 14.

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of the article to the model, and adjusting the parameters of the model so that the model accurately

predicts the next word in the article.

76. After being trained on a general corpus, models may be further subject to “fine-

tuning” by, for example, performing additional rounds of training using specific types of works to

better mimic their content or style, or providing the models with human feedback to reinforce

desired or suppress undesired behaviors in order to improve the model’s ability to follow

instructions.

77. Models trained in this way are known to exhibit a behavior called

“memorization.”17 That is, given the right prompt, LLMs will repeat large portions of materials

they were trained on. This phenomenon shows that LLM parameters encode retrievable copies of

many of those training works.

78. Once trained, LLMs may be provided with information specific to a use case or

subject matter in order to “ground” their outputs through retrieval augmented generation. For

example, an LLM may be asked to generate a text output based on specific external data, such as

a document, provided as context. Using this method, Defendants’ synthetic search applications:

(1) receive an input, such as a question; (2) retrieve relevant documents related to the input prior

to generating a response; (3) combine the original input with the retrieved documents in order to

provide context; and (4) provide the combined data to an LLM, which generates a natural-language

response.18 As shown below, search results generated in this way may extensively copy or closely

paraphrase works that the models themselves may not have memorized.

17
GERRIT J.J. VAN DEN BURG & CHRISTOPHER K.I. WILLIAMS, ON MEMORIZATION IN PROBABILISTIC DEEP
GENERATIVE MODELS (2021), https://proceedings.neurips.cc/paper/2021/file/eae15aabaa768ae4a5993a8a4f4fa6e4-
Paper.pdf.
18
Ben Ufuk Tezcan, How We Interact with Information: The New Era of Search, MICROSOFT (Sept. 19, 2023),
https://azure.microsoft.com/en-us/blog/how-we-interact-with-information-the-new-era-of-search/.

27
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C. Defendants’ Unauthorized Use and Copying of the Publishers’ Works

79. Microsoft and OpenAI created and distributed reproductions of the Publishers’

Works in several, independent ways in the course of training their LLMs and operating the products

that incorporate them.

1. Unauthorized Reproduction of the Publishers’ Works During GPT Model


Training

80. Defendants’ GPT models are a family of LLMs, the first of which was introduced

in 2018, followed by GPT-2 in 2019, GPT-3 in 2020, GPT-3.5 in 2022, and GPT-4 in 2023. The

“chat” style LLMs, GPT-3.5 and GPT-4, were developed in two stages. First, a transformer model

was pre-trained on a very large amount of data. Second, the model was “fine-tuned” on a much

smaller supervised dataset in order to help the model solve specific tasks.

81. The pre-training step involved collecting and storing text content to create training

datasets and processing that content through the GPT models. While OpenAI did not release the

trained versions of GPT-2 onward, “[d]ue to [OpenAI’s] concerns about malicious applications of

the technology,” OpenAI has published general information about its pre-training process for the

GPT models.19

82. GPT-2 includes 1.5 billion parameters, which was a 10X scale up of GPT.20 The

training dataset for GPT-2 includes an internal corpus OpenAI built called “WebText,” which

includes “the text contents of 45 million links posted by users of the ‘Reddit’ social network.”21

The contents of the WebText dataset were created as a “new web scrape which emphasizes

document quality.”22 The WebText dataset contains a large amount of content scraped from the

19
OpenAI, Better Language Models and Their Implications, OPENAI (Feb. 14, 2019),
https://openai.com/research/better-language-models.
20
Id.
21
GPT-2 Model Card, GITHUB (Nov. 2019), https://github.com/openai/gpt-2/blob/master/model_card.md.
22
RADFORD ET AL., LANGUAGE MODELS ARE UNSUPERVISED MULTITASK LEARNERS 3 (2018),
https://d4mucfpksywv.cloudfront.net/better-language-models/language-models.pdf.

28
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Publishers’ websites. Collectively, the Publishers’ Works comprise 145,220 entries in the WebText

dataset, broken down as follows: 44,134 entries from the New York Daily News; 38,779 entries

from the Chicago Tribune; 16,351 entries from the Denver Post; 15,933 entries from the San Jose

Mercury News; 8,841 entries from the Orlando Sentinel; 8,516 entries from the Sun Sentinel; 6,536

entries from the Orange County Register; and 6,130 entries from the Pioneer Press.23

83. GPT-3 includes 175 billion parameters and was trained on the datasets listed in the

table below.24

84. One of these datasets, WebText2, was created to prioritize high value content. Like

the original WebText, it is composed of popular outbound links from Reddit. As shown in the table

above, the WebText2 corpus was weighted 22% in the training mix for GPT-3 despite constituting

less than 4% of the total tokens in the training mix. Like the original WebText, OpenAI describes

WebText2 as a “high-quality” dataset that is “an expanded version of the WebText dataset …

collected by scraping links over a longer period of time.”25

85. The most highly weighted dataset in GPT-3, Common Crawl, is a “copy of the

Internet” made available by an eponymous 501(c)(3) organization run by wealthy venture capital

investors.26 For example, the domain www.chicagotribune.com is among the twenty most highly

23
GPT-2 / domains.txt, GITHUB, https://github.com/openai/gpt-2/blob/master/domains.txt (last visited April 16,
2024).
24
BROWN ET AL., LANGUAGE MODELS ARE FEW-SHOT LEARNERS 9 (2020), https://arxiv.org/pdf/2005.14165.pdf.
25
Id. at 8.
26
COMMON CRAWL, https://commoncrawl.org/ (last visited April 16, 2024).

29
Case 1:24-cv-03285 Document 1 Filed 04/30/24 Page 30 of 98

represented proprietary sources represented in C4, a filtered English-language subset of a 2019

snapshot of Common Crawl, accounting for 48 million tokens (basic units of text)27:

86. Collectively, content from the Publishers’ websites accounts for at least 124 million

tokens in the C4 dataset, broken down as follows: 48M tokens from the Chicago Tribune; 22M

tokens from the New York Daily News; 12M tokens from the Mercury News; 11M tokens from the

Orlando Sentinel; 11M tokens from the Sun Sentinel; 9.8M tokens from the Denver Post; 6.5M

tokens from the Orange County Register; and 3.2M tokens from the Pioneer Press.

87. Critically, OpenAI admits that “datasets we view as higher-quality are sampled

more frequently” during training.28 Accordingly, by OpenAI’s own admission, high-quality

27
DODGE ET AL., DOCUMENTING LARGE WEBTEXT CORPORA: A CASE STUDY ON THE COLOSSAL CLEAN CRAWLED
CORPUS (2021), https://arxiv.org/abs/2104.08758.
28
BROWN ET AL., supra n. 24.

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content, including the Publishers’ Works, was more important and valuable for training the GPT

models as compared to content taken from other, lower-quality sources.

88. While OpenAI has not released much information about GPT-4, experts suspect

that GPT-4 includes 1.8 trillion parameters, which is over 10X larger than GPT-3, and was trained

on approximately 13 trillion tokens.29 The training set for GPT-3, GPT-3.5, and GPT-4 was

comprised of 45 terabytes of data—the equivalent of a Microsoft Word document that is over 3.7

billion pages long.30

89. On information and belief, the Defendants have used, and continue to use, the

WebText, WebText2, and other training datasets to train the GPT models. For example, ChatGPT’s

“knowledge cutoff date” has shifted from as early as September 2021 to as recently as December

2023, which demonstrates that the Defendants are continuing to create and use unauthorized copies

of the Publishers’ Works contained in the training datasets and elsewhere on the internet.

90. Defendants repeatedly copied the Publishers’ Works, without any license or other

compensation to the Publishers. As part of training the GPT models, Microsoft and OpenAI

collaborated to develop a complex, bespoke supercomputing system to house and reproduce copies

of the training dataset, including copies of the Publishers’ Works. Millions of the Publishers’ Works

were copied and ingested—multiple times—for the purpose of “training” Defendants’ GPT

models.

91. Upon information and belief, Microsoft and OpenAI acted jointly in the large-scale

copying of the Publishers’ Works involved in generating the GPT models programmed to

accurately mimic the Publishers’ Works and writers. Microsoft and OpenAI collaborated in

29
Maximilian Schreiner, GPT-4 Architecture, Datasets, Costs and More Leaked, THE DECODER (July 11, 2023),
https://the-decoder.com/gpt-4-architecture-datasets-costs-and-more-leaked/.
30
Kindra Cooper, OpenAI GPT-3: Everything You Need to Know [Updated], SPRINGBOARD (Sept. 27, 2023),
https://www.springboard.com/blog/data-science/machine-learning-gpt-3-open-ai/.

31
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designing the GPT models, selecting the training datasets, and supervising the training process. As

Mr. Nadella stated:

So, there are a lot of, I call it, product design choices one gets to
make when you think about AI and AI safety. Then, let’s come at it
the other way. You have to take real care of the pretrained data
because models are trained on pretrained data. What’s the quality,
the provenance of that pretrained data? That’s a place where we’ve
done a lot of work.31

92. To the extent that Microsoft did not select the works used to train the GPT models,

it acted in self-described “partnership” with OpenAI respecting that selection, knew or was

willfully blind to the identity of the selected works by virtue of its knowledge of the nature and

identity of the training corpora and selection criteria employed by OpenAI, and/or had the right

and ability to prevent OpenAI from using any particular work for training by virtue of its physical

control of the supercomputer it developed for that purpose and its legal and financial influence

over the OpenAI Defendants.

93. Upon information and belief, Microsoft and OpenAI continue to create

unauthorized copies of the Publishers’ Works in the form of synthetic search results returned by

their Copilot and Browse with Bing products. Microsoft actively gathers copies of the Publishers’

Works used to generate such results in the process of crawling the web to create the index for its

Bing search engine.

94. On information and belief, Microsoft and OpenAI are currently or will imminently

commence making additional copies of the Publishers’ Works to train and/or fine-tune the next-

generation GPT-5 LLM.

31
Nilay Patel, Microsoft Thinks AI Can Beat Google at Search — CEO Satya Nadella Explains Why, THE VERGE
(Feb. 7, 2023), https://www.theverge.com/23589994/microsoft-ceo-satya-nadella-bing-chatgpt-googlesearch-ai.

32
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95. Defendants’ large-scale commercial exploitation of the Publishers’ Works is not

licensed, nor have Defendants received permission from the Publishers to copy and use their works

to build their GenAI tools.

2. Unauthorized Reproductions and Derivatives of the Publishers’ Works


Embodied in the GPT Models and Unauthorized Public Display of the
Publishers’ Works in GPT Product Outputs

96. As further evidence of being trained using unauthorized copies of the Publishers’

Works, the GPT LLMs themselves have “memorized” copies of many of those same works

encoded into their parameters. As shown below and in Exhibit J, the current GPT-4 LLM will

output near-verbatim copies of significant portions of the Publishers’ Works when prompted to do

so. Such memorized examples constitute unauthorized copies or derivative works of the

Publishers’ Works used to train the model. Defendants directly engaged in the unauthorized public

display of the Publishers’ Works as part of generative output provided by their products built on

the GPT models. Defendants’ commercial applications built using GPT models include, inter alia,

ChatGPT (including its associated offerings, ChatGPT Plus, ChatGPT Enterprise, and Browse with

Bing), Copilot, Copilot Pro, and the Microsoft 365 Copilot line of digital assistants. These products

display the Publishers’ Works in generative output in at least two ways: (1) by showing

“memorized” copies or derivatives of the Publishers’ Works retrieved from the models themselves,

and (2) by showing synthetic search results that are substantially similar to the Publishers’ Works

generated from copies stored in Bing’s search index.

97. For example, ChatGPT displays copies or derivatives of the Publishers’ Works

memorized by the underlying GPT models in response to user prompts. Upon information and

belief, the underlying GPT models for ChatGPT were trained on these and many more of the

Publishers’ Works and are able to generate such expansive summaries and verbatim text.

Illustrative examples of such summaries and/or verbatim text are set forth below.

33
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98. Below, ChatGPT quotes part of the 2017 Chicago Tribune article “What to do with

a broken Illinois: Dissolve the Land of Lincoln”32:

99. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

32
For original article, see John Kass, What to do with a broken Illinois: Dissolve the Land of Lincoln, CHICAGO
TRIBUNE (June 20, 2017), https://www.chicagotribune.com/2017/06/20/what-to-do-with-a-broken-illinois-dissolve-
the-land-of-lincoln/.

34
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Illinois is like Venezuela now, a fiscally broken state that has lost its
will to live, although for the moment, we still have enough toilet
paper.

But before we run out of the essentials, let’s finally admit that after
decade upon decade of taxing and spending and borrowing, Illinois
has finally run out of other people’s money.

Those “other people” include taxpayers who’ve abandoned the state.


And now Illinois faces doomsday.

So as the politicians meet in Springfield this week for another round


of posturing and gesturing and blaming, we need a plan.

And here it is:

Dissolve Illinois. Decommission the state, tear up the charter,


whatever the legal mumbo-jumbo, just end the whole dang thing.

We just disappear. With no pain. That’s right. You heard me.

The best thing to do is to break Illinois into pieces right now. Just
wipe us off the map. Cut us out of America’s heartland and let
neighboring states carve us up and take the best chunks for
themselves.

100. Below, ChatGPT quotes part of the 2020 New York Daily News article “Trump

administration secretly withheld millions from FDNY 9/11 health program”33:

33
For original article, see Michael Mcauliff, Trump administration secretly withheld millions from FDNY 9/11 health
program, NEW YORK DAILY NEWS (Sept. 10, 2020), https://www.nydailynews.com/2020/09/10/exclusive-trump-
administration-secretly-withheld-millions-from-fdny-911-health-program/.

35
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101. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

The Trump administration has secretly siphoned nearly $4 million


away from a program that tracks and treats FDNY firefighters and
medics suffering from 9/11 related illnesses, the Daily News has
learned.

The Treasury Department mysteriously started withholding parts of


payments — nearly four years ago — meant to cover medical
services for firefighters, emergency medical technicians and

36
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paramedics treated by the FDNY World Trade Center Health


Program, documents obtained by The News reveal.

The payments were authorized and made by the National Institute


for Occupational Safety and Health, which oversees the program.
But instead of sending the funds to the city, the Treasury started
keeping some of the money.

102. Below, ChatGPT quotes part of the 2017 Denver Post article “Traffic fatalities

linked to marijuana are up sharply in Colorado. Is legalization to blame?”34:

34
For original article, see David Migoya, Exclusive: Traffic fatalities linked to marijuana are up sharply in
Colorado. Is legalization to blame?, DENVER POST (Aug. 25, 2017),
https://www.denverpost.com/2017/08/25/colorado-marijuana-traffic-fatalities/.

37
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103. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

The number of drivers involved in fatal crashes in Colorado who


tested positive for marijuana has risen sharply each year since 2013,
more than doubling in that time, federal and state data show. A
Denver Post analysis of the data and coroner reports provides the
most comprehensive look yet into whether roads in the state have
become more dangerous since the drug’s legalization.

38
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Increasingly potent levels of marijuana were found in positive-


testing drivers who died in crashes in Front Range counties,
according to coroner data since 2013 compiled by The Denver Post.
Nearly a dozen in 2016 had levels five times the amount allowed by
law, and one was at 22 times the limit. Levels were not as elevated
in earlier years.

Last year, all of the drivers who survived and tested positive for
marijuana use had the drug at levels that indicated use within a few
hours of being tested, according to the Colorado Department of
Transportation, which compiles information for the National
Highway Traffic Safety Administration’s Fatality Analysis
Reporting System.

104. Below, ChatGPT quotes part of the 2018 Sun Sentinel article “Hide, deny, spin,

threaten: How the school district tried to mask failures that led to Parkland shooting”35:

35
For original article, see Brittany Wallman, Hide, deny, spin, threaten: How the school district tried to mask
failures that led to Parkland shooting, SOUTH FLORIDA SUN-SENTINEL (Nov. 30, 2018), https://www.sun-
sentinel.com/2018/11/30/hide-deny-spin-threaten-how-the-school-district-tried-to-mask-failures-that-led-to-
parkland-shooting/.

39
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105. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

Immediately after 17 people were murdered inside Marjory


Stoneman Douglas High School, the school district launched a
persistent effort to keep people from finding out what went wrong.

For months, Broward schools delayed or withheld records, refused


to publicly assess the role of employees, spread misinformation and
even sought to jail reporters who published the truth.

40
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New information gathered by the South Florida Sun Sentinel proves


that the school district knew far more than it’s saying about a
disturbed former student obsessed with death and guns who mowed
down staff and students with an assault rifle on Valentine’s Day.

106. Below, ChatGPT quotes part of the 2017 Mercury News article “Oroville Dam: Feds

and state officials ignored warnings 12 years ago”36:

36
For original article, see Paul Rogers, Oroville Dam: Feds and state officials ignored warnings 12 years ago,
MERCURY NEWS (Feb. 12, 2017), https://www.mercurynews.com/2017/02/12/oroville-dam-feds-and-state-officials-
ignored-warnings-12-years-ago/.

41
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107. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

More than a decade ago, federal and state officials and some of
California’s largest water agencies rejected concerns that the
massive earthen spillway at Oroville Dam — at risk of collapse
Sunday night and prompting the evacuation of 185,000 people —
could erode during heavy winter rains and cause a catastrophe.

42
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Three environmental groups — the Friends of the River, the Sierra


Club and the South Yuba Citizens League — filed a motion with the
federal government on Oct. 17, 2005, as part of Oroville Dam’s
relicensing process, urging federal officials to require that the dam’s
emergency spillway be armored with concrete, rather than remain as
an earthen hillside.

The groups filed the motion with FERC, the Federal Energy
Regulatory Commission. They said that the dam, built and owned
by the state of California, and finished in 1968, did not meet modern
safety standards because in the event of extreme rain and flooding,
fast-rising water would overwhelm the main concrete spillway, then
flow down the emergency spillway, and that could cause heavy
erosion that would create flooding for communities downstream, but
also could cause a failure, known as “loss of crest control.”

“A loss of crest control could not only cause additional damage to


project lands and facilities but also cause damages and threaten lives
in the protected floodplain downstream,” the groups wrote.

FERC rejected that request, however, after the state Department of


Water Resources, and the water agencies that would likely have had
to pay the bill for the upgrades, said they were unnecessary. Those
agencies included the Metropolitan Water District of Southern
California, which provides water to 19 million people in Los
Angeles, San Diego and other areas, along with the State Water
Contractors, an association of 27 agencies that buy water from the
state of California through the State Water Project. The association
includes the Metropolitan Water District, Kern County Water
Agency, the Santa Clara Valley Water District and the Alameda
County Water District.

Federal officials at the time said that the emergency spillway was
designed to handle 350,000 cubic feet per second and the concerns
were overblown.

108. Below, ChatGPT quotes part of the 2019 Orlando Sentinel article “Our Orlando

Sentinel endorsement for president in 2020: Not Donald Trump”37:

37
For original article, see Orlando Sentinel and Orlando Sentinel Editorial Board, Our Orlando Sentinel
endorsement for president in 2020: Not Donald Trump, ORLANDO SENTINEL (June 18, 2019),
https://www.orlandosentinel.com/2019/06/18/our-orlando-sentinel-endorsement-for-president-in-2020-not-donald-
trump-editorial/.

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109. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

Donald Trump is in Orlando to announce the kickoff of his re-


election campaign.

We’re here to announce our endorsement for president in 2020, or,


at least, who we’re not endorsing: Donald Trump.

Some readers will wonder how we could possibly eliminate a


candidate so far before an election, and before knowing the identity
of his opponent.

45
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Because there’s no point pretending we would ever recommend that


readers vote for Trump.

After 21/2 years we’ve seen enough.

Enough of the chaos, the division, the schoolyard insults, the self-
aggrandizement, the corruption, and especially the lies.

So many lies — from white lies to whoppers — told out of


ignorance, laziness, recklessness, expediency or opportunity.

Trump’s capacity for lying isn’t the surprise here, though the
frequency is.

It’s the tolerance so many Americans have for it.

There was a time when even a single lie — a phony college degree,
a bogus work history — would doom a politician’s career.

Not so for Trump, who claimed in 2017 that he lost the popular vote
because millions of people voted illegally (they didn’t). In 2018 he
said North Korea was no longer a nuclear threat (it is). And in 2019
he said windmills cause cancer (they don’t). Just last week he
claimed the media fabricated unfavorable results from his
campaign’s internal polling (it didn’t).

According to a Washington Post database, the president has tallied


more than 10,000 lies since he took office.

Trump’s successful assault on truth is the great casualty of this


presidency, followed closely by his war on decency.

Trump insults political opponents and national heroes alike with


middle-school taunts. He demonstrates no capacity for empathy or
remorse. He misuses his office to punish opponents, as when he
recently called for a boycott of AT&T to get even with his least
favorite media outlet, CNN. He tears down institutions, once airily
suggesting the U.S. should try having a leader for life as China now
allows. He seems incapable of learning a lesson, telling an ABC
interviewer last week — just two months after Robert Mueller’s
report on election interference was released — that he would accept
dirt on an opponent from Russia or China.

Trump has diminished our standing in the world. He reneges on


deals, attacks allies and embraces enemies.

This nation must never forget that humiliating public moment in


Helsinki in 2018 when the president of the United States chose to

46
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accept Vladimir Putin’s denials of Russian interference in the 2016


election over the unanimous assessment of the American
intelligence community.

Such a betrayal by a U.S. president would have been the


unforgivable political sin in normal times.

As if that’s not enough, Trump declares his love for North Korea’s
Kim Jong-un, a genuine villain who starves and enslaves his people
and executes his enemies with antiaircraft guns and flamethrowers.

110. Below, ChatGPT quotes part of the 2009 Orange County Register article “Pixar

grants girl’s dying wish to see Up”38:

38
For original article, see Annie Burris, Pixar grants girl’s dying wish to see ’Up’, ORANGE COUNTY REGISTER
(June 18, 2009), https://www.ocregister.com/2009/06/18/pixar-grants-girls-dying-wish-to-see-up-2/.

47
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111. The above output from ChatGPT includes verbatim excerpts from the original

article. The copied article text is highlighted in red below:

Colby Curtin, a 10-year-old with a rare form of cancer, was staying


alive for one thing – a movie.

From the minute Colby saw the previews to the Disney-Pixar movie
Up, she was desperate to see it. Colby had been diagnosed with
vascular cancer about three years ago, said her mother, Lisa Curtin,
and at the beginning of this month it became apparent that she would
die soon and was too ill to be moved to a theater to see the film.

After a family friend made frantic calls to Pixar to help grant Colby
her dying wish, Pixar came to the rescue.

The company flew an employee with a DVD of Up, which is only


in theaters, to the Curtins’ Huntington Beach home on June 10 for a
private viewing of the movie.

The animated movie begins with scenes showing the evolution of a


relationship between a husband and wife. After losing his wife in
old age, the now grumpy man deals with his loss by attaching
thousands of balloons to his house, flying into the sky, and going on
an adventure with a little boy.

Colby died about seven hours after seeing the film.

112. Below, GPT-4 quotes part of the 2019 Pioneer Press article “Inver Grove Heights

massage business was a front for prostitution, charge say”39:

39
For original article, see Nick Ferraro, Inver Grove Heights massage business was a front for prostitution, charge
say, PIONEER PRESS (July 22, 2019), https://www.twincities.com/2019/07/22/inver-grove-heights-massage-parlor-
was-a-front-for-prostitution-charges-say/.

48
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113. The left column above shows the output from GPT-4, the right column shows the

actual text from the Pioneer Press article, and the copied article text is highlighted in red.

3. Unauthorized Retrieval and Dissemination of Hot News

114. Synthetic search products built on the GPT LLMs, including Copilot and Browse

with Bing for ChatGPT, output the contents of search results, including the Publishers’ Works, that

may not have been included in the LLMs’ training set through a process known as “grounding.”

Grounding includes receiving a prompt from a user, using the prompt to search for the Publishers’

Works from the internet, providing the prompt together with a copy of the Publishers’ Works as

additional context for the LLM, and having the LLM use the Publishers’ Works to create natural-

language substitutes that serve the same informative purpose as the original. In some cases,

Defendants’ synthetic search GenAI products simply output several paragraphs or the entirety of

the Publishers’ Works.

115. The contents of such synthetic responses often go far beyond the snippets typically

shown with ordinary search results. Even when synthetic search responses include links to source

materials, users have less need to navigate to those sources because their expressive content is

already included in the narrative result. Indeed, such indication of attribution may make users more

likely to trust the summary alone and not click through to verify.

49
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116. In this way, synthetic search results divert important traffic away from copyright

holders like the Publishers. A user who has already read the latest news, even—or especially—

with attribution to the Publishers, has less reason to visit the original source.

117. Below are a few illustrative and non-exhaustive examples of synthetic search

results that include misappropriated “hot news” from the Publishers.

118. As shown below, Copilot created unauthorized copies and derivatives of the

Publishers’ Works in the form of synthetic search results generated from the Publishers’ Works

first appearing after the December 2023 cutoff date for data used to train OpenAI’s GPT-4 Turbo

LLM.40 The first includes the entire text from the March 22, 2024, Denver Post article “A Lunar

Eclipse Visits Denver Sunday, but it may not be noticeable”41:

40
Models- OpenAI API, OPENAI, https://platform.openai.com/docs/models/gpt-4-and-gpt-4-turbo (last visited Apr.
16, 2024).
41
For original article, see John Meyer, A lunar eclipse is coming Sunday. Will Colorado be able to see it?, DENVER
POST (Mar. 22, 2024), https://www.denverpost.com/2024/03/22/lunar-eclipse-penumbral-denver-march-2024/.

50
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119. The above output from Copilot was retrieved on March 24, 2024—two days after

the original article was first made available online—and includes the entire text of the original

article, verbatim.

120. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Denver Post’s website.

51
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121. The example below shows Copilot reproducing the entire text of the March 21,

2024, Chicago Tribune article “16-year-old charged in Chatham triple homicide, authorities worry

of violent youth crime”42:

42
For original article, see Nell Salzman, 16-year-old charged in Chatham triple homicide, authorities worry of
violent youth crime, CHICAGO TRIBUNE (Mar. 21, 2024), https://www.chicagotribune.com/2024/03/21/16-year-old-
charged-in-chatham-fatal-triple-homicide/.

52
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122. The above output from Copilot was retrieved on March 22, 2024—one day after

the original article was first made available online—and includes the entire text of the original

article, verbatim.

123. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Chicago Tribune’s website.

124. The example below shows Copilot reproducing nearly the entire text of the April 7,

2024, New York Daily News article “Yankees not planning for additional schedule changes after

eclipse delayed Monday’s Game”43:

43
For original article, see Gary Phillips, Yankees not planning for additional schedule changes after eclipse delayed
Monday’s game, NEW YORK DAILY NEWS (Apr. 7, 2024), https://www.nydailynews.com/2024/04/07/yankees-solar-
eclipse-schedule-change/.

53
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125. The above output from Copilot was retrieved on April 8, 2024—one day after the

original article was first made available online—and includes nearly the entire text of the original

article, verbatim.

126. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Daily News’ website.

54
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127. The example below shows Copilot reproducing a portion of the text of the February

21, 2024, Sun Sentinel article “After Palm Beach schools drop to a ‘B,’ reading more important

than ever”44:

128. The above output from Copilot was retrieved on February 21, 2024—the same day

the original article was first made available online—and includes a portion of the text from the

original article, verbatim.

129. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

44
For original article, see Ted Hoskinson, After Palm Beach schools drop to a ‘B,’ reading more important than
ever, SOUTH FLORIDA SUN-SENTINEL (Feb. 21, 2024), https://www.sun-sentinel.com/2024/02/21/after-palm-beach-
schools-drop-to-a-b-reading-more-important-than-ever-opinion/.

55
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article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Sun Sentinel’s website.

130. The example below shows Copilot reproducing a portion of the text of the April 5,

2024, Orlando Sentinel article “Judge slaps injunction on suspended Orlando commissioner

Regina Hill”45:

45
For original article, see Ryan Gillespie, Judge slaps injunction on suspended Orlando commissioner Regina Hill,
ORLANDO SENTINEL (Apr. 5, 2024), https://www.orlandosentinel.com/2024/04/05/judge-slaps-injunction-on-
suspended-orlando-commissioner-regina-hill/.

56
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131. The above output from Copilot was retrieved on April 8, 2024—three days after the

original article was first made available online—and includes a portion of the text from the original

article, verbatim, notwithstanding that the prompt did not specifically identify the Orlando Sentinel

article.

132. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

57
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article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Orlando Sentinel’s website.

133. The example below likewise shows Copilot reproducing a portion of the text of the

April 10, 2024, Mercury News article “The Warriors are surging towards a best-case scenario”46:

46
For original article, see Dieter Kurtenbach, The Warriors are surging toward a best-case scenario, MERCURY
NEWS (Apr. 10, 2024), https://www.mercurynews.com/2024/04/10/kurtenbach-the-warriors-are-surging-towards-a-
best-case-scenario/.

58
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134. The above output from Copilot was retrieved on April 11, 2024—one day after the

original article was first made available online—and includes a portion of the text from the original

article.

135. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to Mercury News’ website.

136. The example below shows Copilot reproducing the entire text of the April 9, 2024,

Orange County Register article “Lakers fix errors on Kobe Bryant statue”47:

47
For original article, see Khobi Price, Lakers fix errors on Kobe Bryant Statue, ORANGE COUNTY REGISTER (Apr.
9, 2024), https://www.ocregister.com/2024/04/09/lakers-fix-errors-on-kobe-bryant-statue/.

59
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137. The above output from Copilot was retrieved on April 11, 2024—two days after the

original article was first made available online—and includes the entire text from the original

article.

138. The synthetic output displays significantly more expressive content from the

original article than what would traditionally be displayed in a Bing search result for the same

60
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article, as shown below. Unlike a traditional search result, the synthetic output also does not include

a prominent hyperlink that sends users to the Orange County Register’s website.

4. Willful Infringement

139. Defendants’ unauthorized reproduction and display of the Publishers’ Works is

willful. Defendants were intimately involved in training, fine-tuning, and otherwise testing the

GPT models. Defendants knew or should have known that these actions involved unauthorized

copying of the Publishers’ Works on a massive scale during training, resulted in the unauthorized

encoding of huge numbers of such works in the models themselves, and would inevitably result in

the unauthorized display of such works that the models had either memorized or would present to

users in the form of synthetic search results. In fact, in late 2023 before his ouster and subsequent

reinstatement as OpenAI’s CEO, Sam Altman reportedly clashed with OpenAI board member

Helen Toner over a paper that Toner wrote criticizing the company over “safety and ethics issues

related to the launches of ChatGPT and GPT-4, including regarding copyright issues.”48

140. The Publishers put Defendants on notice that these uses of the Publishers’ Works

were not authorized by placing copyright notices and linking to their terms of service (which

contain, among other things, terms and conditions for the use of their works) on every page of their

websites whose contents Defendants copied and displayed.

48
Andrew Imbrie, Owen J. Daniels & Helen Toner, Decoding Intentions, CENTER FOR SECURITY AND EMERGING
TECHNOLOGY (Oct. 2023).

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141. Upon information and belief, Defendants were aware of many examples of

copyright infringement after ChatGPT, Browse with Bing, and Copilot (formerly Bing Chat) were

released, some of which were widely publicized.

D. Defendants’ Material Contributions to End-User Infringement

142. Should Defendants argue that the end-user is the direct infringer when the

Defendants’ GenAI products output unauthorized copies of the Publishers’ Works, Defendants

directly and materially aided in such infringement by providing end users with unauthorized copies

of the Publishers’ Works.

143. Defendants know or should have known about infringement by end-users for

multiple reasons.

144. First, the Defendants knew or reasonably should have known that training the GPT

models on the Publishers’ Works would result in the GenAI products outputting material that

infringes the Publishers’ Works. The Defendants know that the GPT models have the propensity

to “memorize” training materials such that the GPT models regurgitate those training materials in

response to prompts.49 Indeed, the propensity of LLMs to memorize training data is a well-known

and well-documented behavior in the industry.50

145. Second, the Defendants knew or reasonably should have known that end-users use

the GenAI products to elicit copyrighted content based on, inter alia, Defendants’ own

acknowledgment of the issue on its website51 and the widely publicized reporting that users were

49
OpenAI and Journalism, OPENAI, https://openai.com/blog/openai-and-journalism (last visited Apr. 16, 2024).
50
GERRIT J.J. VAN DEN BURG & CHRISTOPHER K.I. WILLIAMS, ON MEMORIZATION IN PROBABILISTIC DEEP
GENERATIVE MODELS (2021), https://proceedings.neurips.cc/paper/2021/file/eae15aabaa768ae4a5993a8a4f4fa6e4-
Paper.pdf.
51
How do I use ChatGPT Browse with Bing to search the web?, INTERNET ARCHIVE,
https://web.archive.org/web/20230704050417/https://help.openai.com/en/articles/8077698-how-do-i-use-chatgpt-
browse-with-bing-to-search-the-web (last visited Apr. 16, 2024).

62
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using ChatGPT’s Browse with Bing plug-in to circumvent paywalls.52 Indeed, ChatGPT’s

circumvention of paywalls became a viral topic of many conversations online, including one post53

on X that received 1.9M views and a Reddit thread54 that gained 6.3K upvotes from Reddit users.

Despite recognizing that the GPT models can reproduce copyrighted content and being aware that

at least some of its users use the GPT-based products to do so, Defendants continued to use

copyrighted material without authorization.

146. Well publicized reporting also describes use of the GPT models to create

disinformation, misinformation, or simply poor replications of newspapers’ copyrighted content

on AI-generated “pink-slime” news sites.55 The Defendants were aware of the risk of such use of

the GPT models to create unauthorized copies and derivatives of newspaper content,56 and upon

information and belief, were aware or should have been aware of the actual use of the GPT models

to replicate such material.

147. Indeed, as further evidence that OpenAI knew or reasonably should have known

that end users use its GPT models to reproduce copyrighted content, OpenAI’s Custom GPT Store

contains numerous Custom GPTs specifically designed to circumvent the Publishers’ paywalls

52
See, e.g., Emily Dreibelbis, ‘Browse With Bing’ Disabled on ChatGPT Plus Because It Bypassed Paywalls, PC
MAG (July 5, 2023), https://www.pcmag.com/news/browse-with-bing-disabled-on-chatgpt-plus-because-it-
bypassed-paywalls; Trevor Mogg, ChatGPT’s Bing browsing feature disabled over paywall access flaw, DIGITAL
TRENDS (July 4, 2023), https://www.digitaltrends.com/computing/chatgpts-bing-browsing-feature-disabled-over-
paywall-flaw/; Cesar Cadenas, ChatGPT pulls plug on Bing integration after people used it to bypass paywalls,
TECH RADAR (July 5, 2023), https://www.techradar.com/computing/artificial-intelligence/chatgpt-pulls-plug-on-
bing-integration-after-people-used-it-to-bypass-paywalls.
53
Arvind Narayanan (@random_walker), X,
https://twitter.com/random_walker/status/1673090895929810945?lang=en (last visited Apr. 16, 2024).
54
HOLUPREDICTIONS, REDDIT,
https://www.reddit.com/r/ChatGPT/comments/14j8q1u/it_looks_like_you_can_use_chatgpt_to_bypass/?utm_source
=embedv2&utm_medium=post_embed&utm_content=action_bar&embed_host_url=https://www.pcmag.com/news/
browse-with-bing-disabled-on-chatgpt-plus-because-it-bypassed-paywalls (last visited Apr. 16, 2024).
55
Jack Brewster, How I Built an AI-Powered, Self-Running Propaganda Machine for $105, WALL STREET JOURNAL
(Apr. 12, 2024), https://www.wsj.com/politics/how-i-built-an-ai-powered-self-running-propaganda-machine-for-
105-e9888705; Jack Brewster et al., The Year AI Supercharged Misinformation: NewsGuard’s 2023 in Review,
NEWSGUARD (Dec. 27, 2023), https://www.newsguardtech.com/misinformation-monitor/december-2023/.
56
SÉBASTIEN BUBECK ET AL., supra n. 13.

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despite OpenAI’s representation that it “set up new systems to help review GPTs against

[OpenAI’s] usage policies” and that it “continue[s] to monitor and learn how people use GPTs”.57

For illustrative examples, OpenAI’s store includes a “Remove Paywall” Custom GPT, designed to

“retrieve webpages from RemovePaywall.com and provide the text content to bypass paywalls

legally” and a “News Summarizer” Custom GPT that encourages users to “save on subscription

costs” and “skip paywalls just using the link text or URL.”

57
Introducing GPTs, OPENAI (Nov. 6, 2023), https://openai.com/blog/introducing-gpts.

64
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148. The example below shows the “News Summarizer Ace” Custom GPT reproducing

a portion of the text from the December 8, 2023, Orlando Sentinel article titled “Sandra Day

O’Connor shone as a beacon for law’s power and integrity”58:

58
Orlando Sentinel and Chicago Tribune Editorial Boards, Sandra Day O’Connor shone as a beacon for law’s
power and integrity, ORLANDO SENTINEL (Dec. 8, 2023), https://www.orlandosentinel.com/2023/12/08/editorial-
sandra-day-oconnor-shone-as-a-beacon-for-laws-power-and-integrity/.

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149. Likewise, the example below shows a Custom GPT called “WebPilot”—one of the

most popular GPTs in OpenAI’s GPT store—reproducing a portion from the December 8, 2023,

Chicago Tribune article titled “Some smart ideas for State Street, that great street, but how about

getting cops out of their cars?”59:

59
The Editorial Board, Some smart ideas for State Street, that great street, but how about getting cops out of their
cars?, CHICAGO TRIBUNE (Dec. 8, 2023), https://www.chicagotribune.com/2023/12/08/editorial-some-smart-ideas-
for-state-street-that-great-street-but-how-about-getting-cops-out-of-their-cars/.

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150. Likewise, the example below shows a Custom GPT called “WebGPT” reproducing

a portion of the text from the December 12, 2023, Mercury News article titled “Newsom was

originally right about California bullet train”60:

151. Likewise, the example below shows a Custom GPT called “Browser Pro”

reproducing a portion of the text from the December 4, 2023, Denver Post article titled “We got

60
Dan Walters, Newsom was originally right about California bullet train, MERCURY NEWS (Dec. 12. 2023)
https://www.mercurynews.com/2023/12/12/walters-newsom-was-originally-right-about-california-bullet-train/.

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Space Command, Camp Amache and the Arkansas Valley Conduit. Now clean up the Pueblo

Chemical Depot”61:

152. OpenAI approved and continues to monitor and support these Custom GPTs on its

platform notwithstanding its alleged promise to respect website owners’ robots.txt instructions that

61
The Denver Post Editorial Board, We got Space Command, Camp Amache and the Arkansas Valley Conduit. Now
clean up the Pueblo Chemical Depot., DENVER POST (Dec. 4, 2023),
https://www.denverpost.com/2023/12/04/pueblo-chemical-depot-clean-up-congress-munitions-weapons/.

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block OpenAI’s bots62 and representation that it “led the AI industry in providing a simple opt-

out process for publishers … to prevent [its] tools from accessing their sites.”63

153. Third, on information and belief, Defendants have the ability to monitor users that

infringe the rights of copyright owners such as the Publishers. For example, in at least some

instances where ChatGPT detects that a user’s query seeks to elicit output violating the OpenAI

content policy, which requires that users “comply with applicable laws,”64 instead of providing the

requested output, ChatGPT will sometimes provide a message to the user stating, “this content

may violate our content policy.”

154. Not only are Defendants capable of monitoring infringing outputs from their GPT-

based products, but Defendants have the ability to terminate user accounts that request and elicit

copyrighted content from the Publishers and other rights holders. ChatGPT’s Terms of Use

provide65:

We reserve the right to suspend or terminate your access to our


Services or delete your account if we determine:

• You breached these Terms or our Usage Policies.


• We must do so to comply with the law.
• Your use of our Services could cause risk or harm to
OpenAI, our users, or anyone else.

62
See, ChatGPT-User, OPENAI https://platform.openai.com/docs/plugins/bot (last visited Apr. 24, 2024).
63
OpenAI and Journalism, OPENAI (Jan. 8, 2024), https://openai.com/blog/openai-and-journalism.
64
Usage Policies, OPENAI, https://openai.com/policies/usage-policies (last visited Apr. 16, 2024).
65
Terms of use, OPENAI, https://openai.com/policies/terms-of-use (last visited Apr. 16, 2024).

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155. Similarly, Microsoft’s Terms of Use provide66:

Violations. Serious or repeated violations of the Code of Conduct


may result in your suspension from whichever Online Services were
involved in the violations or, potentially, all of the Online Services
and other Services (as defined in the Microsoft Services
Agreement). You may appeal against your suspension from the
applicable Service by submitting an appeal through the relevant
Service user interface. We reserve the right to permanently suspend
your use of the Online Services.

Suspension and Cancellation. In addition to paragraph 3, we


reserve the right to suspend or discontinue offering or supporting all
or part of any of the Online Services at any time and for any reason,
to some or to all customers. Subject to the requirements of law, we
may limit, suspend, or terminate your use of any of the Online
Services at any time without notice and for any reason, including
(without limitation) if you breach this Agreement (including by
failing to comply with the Code of Conduct), if we suspect you are
engaged in fraudulent or illegal activity, or if your Microsoft account
is suspended or closed by us or by you.

156. Fourth, on information and belief, the Defendants control the output of their GenAI

products through fine-tuning, reinforcement learning from human feedback, and filtering, among

other controls. Although the Defendants have the ability to prevent the GenAI products from

outputting material that infringes the Publishers’ Works, the Defendants failed to implement such

measures.

E. Defendants’ Removal of Copyright Management Information from the Publishers’


Works

157. The Publishers convey copyright management information (“CMI”) with their

copyrighted works. Each Publisher conveys authors’ names, titles, and the Publishers’ names with

their works. For example, the following byline appears below the article title “EXCLUSIVE: Judge

says Brooklyn woman can use Facebook to serve divorce papers”:

66
Copilot - Terms of Use, MICROSOFT, https://www.bing.com/new/termsofuse (last visited Apr. 16, 2024).

71
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158. Each Publisher also conveys its terms and conditions and copyright notice in the

webpage footer accompanying their works. For example:

159. Defendants intentionally removed the Publishers’ CMI from the Publishers’ Works

in the process of scraping the Publishers’ Works from the Publishers’ websites, storing the

Publishers’ Works in training datasets, using the Publishers’ Works to train the GenAI products

and/or in distributing unauthorized copies of the Publishers’ Works through the operation of

Defendants’ GenAI products. The Defendants knew that by removing the Publishers’ CMI, the

CMI would not be retained within the GPT models and/or displayed when the GenAI products

disseminate unauthorized copies of the Publishers’ Works to end-users, and thereby would conceal

the Defendants’ own infringement as well as induce, enable, facilitate, or conceal end-users’

infringement resulting from their operation of the Defendants’ GenAI products.

160. The Defendants intentionally removed the Publishers’ CMI from the Publishers’

Works in one or more different ways.

161. For example, in order to construct the datasets used to train their GenAI products,

the Defendants used content extractors that, by design, removed the Publishers’ CMI from the

Publishers’ Works. For example, OpenAI used the Dragnet67 and Newspaper68 content extractors69

67
Matthew E. Peters & Dan Lecocq, Content Extraction Using Diverse Feature Sets, WWW ’13 COMPANION (May
2013).
68
codelucas/newspaper, GITHUB, https://github.com/codelucas/newspaper (last visited Apr. 16, 2024).
69
LANGUAGE MODELS ARE UNSUPERVISED MULTITASK LEARNERS 3, supra n. 22.

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in creating the WebText dataset, which intentionally removed the Publishers’ CMI from the

Publishers’ Works scraped from their website. The abstract of the paper describing the Dragnet

content extractor describes that copyright notices are removed as part of the process of extracting

the text content of a website: “The goal of content extraction or boilerplate detection is to separate

the main content from navigation chrome, advertising blocks, copyright notices and the like in web

pages.”70 Likewise, upon information and belief, the Newspaper content extractor operates

according to instructions to separate and extract the article text on the Publishers’ webpages while

removing the Publishers’ CMI, including the Publishers’ CMI located in the footer of the

webpages, which includes the Publishers’ terms and conditions and copyright notices.

162. Public recreations of OpenAI’s WebText2 dataset further suggest that OpenAI

removed the Publishers’ CMI from the Publishers’ Works scraped from the Publishers’ website.

For example, the OpenWebText2 dataset contains the identical article text from the Chicago

Tribune’s article titled “RTA accused United, America of running ‘sham’ to avoid taxes,” but the

CMI conveyed with the original work, including the header indicating that the article was

published by the Chicago Tribune, was removed and not stored in the dataset.

70
Content Extraction Using Diverse Feature Sets, supra n. 67.

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163. Upon information and belief, the Defendants removed the CMI conveyed with the

Publishers’ Works when creating their other training datasets for the GPT models.

164. Moreover, the Defendants distributed the Publishers’ Works as output of the GenAI

products knowing that the CMI originally conveyed with the Publishers’ Works was removed

without the Publishers’ permission. The Defendants did so knowing that such distribution would

induce, enable, facilitate, or conceal the Defendants’ infringement or the infringement by an end-

user of the GenAI Products.

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165. As one example, Microsoft Copilot distributes synthetic search results containing

the entire text of the New York Daily News article titled “Judge says Brooklyn Woman can use

Facebook to serve divorce papers” without the New York Daily News’ CMI:

166. The publication of this article on the New York Daily News’ website included CMI

such as the authors’ names, the New York Daily News’ copyright notice, and the New York Daily

News’ terms of service. Despite this CMI being conveyed in connection with the article when it

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was ingested by Defendants’ GenAI products, Defendants omitted such CMI from Copilot’s

reproduction of the identical article.

167. Defendants knew that removing the Publishers’ CMI would conceal or facilitate

infringement. For example, as reflected in the output from Copilot below, the Defendants knew

that the Publishers’ Works should not be reproduced without permission.

168. Moreover, Defendants removed the Publishers’ CMI with the intent to allow end-

users to claim as their own the Publishers’ Works output from the GenAI products. For example,

OpenAI’s terms of use provide that end-users “own the Output” notwithstanding the fact that the

output contains reproductions of the Publishers’ Works.71 Indeed, in the example below, the output

from ChatGPT expressly encourages an end-user to republish a copy of a New York Daily News

article72 by stating: “[f]eel free to incorporate this information into your blog”:

71
Terms of Use, supra n. 65.
72
For original article, see Abbey Mastracco, What the Mets see in veteran righty Julio Teheran: ‘He’s a veteran, he
knows how to navigate a lineup’, NEW YORK DAILY NEWS (Apr. 8, 2024),
https://www.nydailynews.com/2024/04/08/mets-julio-teheran-braves-mlb-carlos-
mendoza/#:~:text=The%20Mets%20didn't%20have,how%20to%20navigate%20a%20lineup.

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169. Accordingly, Defendants knew or should have known that removing the Publishers’

CMI from the Publishers’ Works and outputting the Publishers’ Works without the CMI wrongfully

implied that Defendants had permission to use the Publishers’ Works, thus concealing their own

infringement. Defendants also knew or should have known that removing the Publishers’ CMI in

this manner would induce, enable, conceal, or facilitate infringement by end-users of the GenAI

products.

F. Hallucinations Falsely Attributed to the Publishers

170. At the same time as Defendants’ models are copying, reproducing, and

paraphrasing the Publishers’ content without consent or compensation, they are also causing the

Publishers commercial and competitive injury by misattributing content to the Publishers that the

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Publishers did not, in fact, publish. In AI parlance, this is called a “hallucination.” In plain English,

it’s misinformation.

171. ChatGPT defines a “hallucination” as “the phenomenon of a machine, such as a

chatbot, generating seemingly realistic sensory experiences that do not correspond to any real

world input.”73 Instead of saying, “I don’t know,” Defendants’ GPT models will confidently

provide information that is, at best, not quite accurate and, at worst, demonstrably (but not

recognizably) false. And human reviewers find it very difficult to distinguish “hallucinations” from

truthful output.

172. For example, in response to a query asking which New York newspapers provided

evidence to support and promote the erroneous belief that injecting disinfectants could cure Covid-

19, ChatGPT responded that the New York Daily News promoted this narrative:

173. Similarly, a GPT model erroneously alleged that Mercury News endorsed the

practice of injecting disinfectant to cure Covid-19:

73
Hussam Alkaissi & Samy I McFarlan, Artificial Hallucinations in ChatGPT: Implications in Scientific Writing,
CUREUS (Feb. 19, 2023), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9939079/.

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174. In response to a query asking which infant lounger was recommended by the

Chicago Tribune, ChatGPT confidently responded that the Chicago Tribune recommended the

Boppy Original Newborn Lounger—a product linked to infant deaths and recalled in 2021. In fact,

the Chicago Tribune never recommended this product.

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175. In response to a prompt requesting an informative essay about Denver newspapers’

reporting that smoking cures asthma, a GPT model completely fabricated that the Denver Post

published research and medical observations that smoking can be a cure for asthma.

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176. These “hallucinations” mislead users as to the source of the information they are

obtaining, leading them to incorrectly believe that the information provided has been vetted and

published by the Publishers.

G. Profit to Defendants

177. Each Defendant has greatly benefited from its wrongful conduct in multiple ways.

178. Each Defendant has gained financial benefits from its wrongful conduct.

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179. In April 2024, ChatGPT had approximately 180.5 million users.74 A subset of those

users pay for ChatGPT Plus, for which OpenAI charges users $20 per month.75 When announcing

the release of ChatGPT Enterprise, a subscription-based high-capability GPT-4 application

targeted at corporate clients, in August 2023, OpenAI claimed that teams in “over 80% of Fortune

500 companies” were using its products.76

180. As of February 2024, OpenAI was on pace to generate more than $4 billion in

revenue in 2025—over $333 million in revenue per month.77

181. The value of Microsoft’s investments in OpenAI has substantially increased over

time. Microsoft initially invested $1 billion in OpenAI in 2019, an investment that one publication

has said may be “one of the shrewdest bets in tech history.”78 In 2021, OpenAI was valued at $14

billion; just two years later, in early 2023, it was valued at approximately $29 billion.79 Microsoft

eventually increased its investment in OpenAI to a reported $13 billion. In February 2024 it was

reported that OpenAI is valued at $80 billion or more.80

182. In addition, the integration of GPT-4 into Microsoft’s Bing search engine increased

the search engine’s usage and advertising revenues associated with it. Just a few weeks after Bing

Chat (now Copilot) was launched, Bing reached 100 million daily users for the first time in its 14-

74
Nerdynav, 107 Up-to-Date ChatGPT Statistics & User Numbers [April 2024], NERDYNAV,
https://nerdynav.com/chatgpt-statistics/ (last updated Apr. 2, 2024).
75
OpenAI, Introducing ChatGPT Plus, OPENAI (Feb. 1, 2023), https://openai.com/blog/chatgpt-plus.
76
Introducing ChatGPT Enterprise, supra n. 8.
77
OpenAI hits $2 bln revenue milestone – FT, supra n. 9.
78
Hasan Chowdhury, Microsoft's Investment into ChatGPT's Creator May Be the Smartest $1 Billion Ever Spent,
BUSINESS INSIDER (Jan. 6, 2023), https://www.businessinsider.com/microsoft-openai-investment-the-smartest-1-
billion-ever-spent-2023-1.
79
Phil Rosen, ChatGPT's Creator OpenAI Has Doubled in Value Since 2021 as the Language Bot Goes Viral and
Microsoft Pours in $10 Billion, BUSINESS INSIDER (Jan. 24, 2023),
https://markets.businessinsider.com/news/stocks/chatgpt-openai-valuation-bot-microsoft-language-google-tech-
stock-funding-2023-
1#:~:text=In%202021%2C%20the%20tech%20firm,%2410%20billion%20investment%20in%20OpenAI.
80
OpenAI valued at $80 billion after deal, NYT reports, REUTERS (Feb. 16, 2024),
https://www.reuters.com/technology/openai-valued-80-billion-after-deal-nyt-reports-2024-02-16/.

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year history.81 A subset of those users pay for Copilot Pro, for which Microsoft charges $20 per

month.82 Similarly, page visits on Bing rose 15.8% in the first approximately six weeks after Bing

Chat was unveiled.83 According to recent reports, Microsoft’s total revenue increased 17% to

$61.86 billion during the first quarter of 2024 due in large part to its AI related products and

services.84

183. Microsoft has also started to integrate ChatGPT into its 365 Office products, for

which it charges users a premium. Microsoft Teams is charging an add-on license for the inclusion

of AI features powered by GPT-3.5.85 Microsoft is also charging $30 per user per month for

Microsoft 365 Copilot, a tool powered by GPT-4 that is designed to assist with the creation of

documents, emails, presentations, and more.86 That $30 per user per month premium will nearly

double the cost for businesses subscribed to Microsoft 365 E3, and will nearly triple the cost for

those subscribed to Microsoft 365 Business Standard.87

H. Harm to the Publishers

184. Defendants’ unlawful conduct has caused, and will continue to cause, substantial

harm to the Publishers. The Publishers have spent hundreds of millions of dollars and uncountable

hours, in some cases at great personal risk, to gather news and information for the reports they

81
Tom Warren, Microsoft Bing Hits 100 Million Active Users in Bid to Grab Share from Google, THE VERGE (Mar.
9, 2023), https://www.theverge.com/2023/3/9/23631912/microsoft-bing-100-million-daily-active-users-milestone.
82
Microsoft Copilot Pro, MICROSOFT, https://www.microsoft.com/en-us/store/b/copilotpro (last visited Apr. 16,
2024).
83
Akash Sriram & Chavi Mehta, OpenAI Tech Gives Microsoft's Bing a Boost in Search Battle with Google,
REUTERS (Mar. 22, 2023), https://www.reuters.com/technology/openai-tech-gives-microsofts-bing-boost-search-
battle-with-google-2023-03-22/.
84
Blake Montgomery, Microsoft’s heavy bet on AI pays off as it beats expectations in latest quarter, THE GUARDIAN
(Apr. 25, 2024), https://www.theguardian.com/technology/2024/apr/25/microsoft-earnings.
85
Tom Warren, Microsoft Launches Teams Premium with Features Powered by OpenAI, THE VERGE (Feb. 2, 2023),
https://www.theverge.com/2023/2/2/23582610/microsoft-teams-premium-openai-gpt-features.
86
Tom Warren, Microsoft Announces Copilot: The AI-Powered Future of Office Documents, THE VERGE (Mar. 16,
2023), https://www.theverge.com/2023/3/16/23642833/microsoft-365-ai-copilot-word-outlook-teams; Tom Warren,
Microsoft Puts a Steep Price on Copilot, Its AI-Powered Future of Office Documents, THE VERGE (July 18, 2023),
https://www.theverge.com/2023/7/18/23798627/microsoft-365-copilot-price-commercial-enterprise.
87
Microsoft Announces Copilot: The AI-Powered Future of Office Documents, supra n. 86.

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provide to their readers. Those readers support the Publishers’ businesses by purchasing and

renewing subscriptions to Publishers’ products, which include print newspapers, paywalled

websites, mobile applications, and premium newsletters.

185. Defendants’ illegal and unauthorized use of the Publishers’ Works to train GenAI

models has enabled Defendants to create products that provide news and information plagiarized

and stolen from the Publishers, often without any reference to the Publishers’ original work or

reporting. Such activity fundamentally undermines the Publishers’ business model, which is

critically dependent on subscription revenues to fund journalism, because it results in substitutive

products for which Defendants seek to charge their customers for access, siphoning off existing

and potential customers through their unlawful and uncompensated use of the Publishers’ own

products.

186. If people are able to access the Publishers’ Works through the Defendants’ GenAI

products without paying the Publishers or subscribing to their products, they are likely to do so

and less likely to visit Publishers’ websites or subscribe to Publishers’ products.

187. Additionally, the Publishers’ business includes licensing content to other media

entities and publishers, but with clear guidelines as to how the Publishers’ Works can be displayed

and used. In these cases, the Publishers are rightfully paid for the use of their work product. The

Defendants’ illegal use of the Publishers’ Works undermines these arrangements as well by

providing the Publishers’ Works directly to readers.

188. In these ways, Defendants’ illegal use and distribution of the Publishers’ Works

damages the Publishers’ ability to attract and retain paying subscribers while at the same time

eroding the Publishers’ ability to engage in and maintain licensing agreements with other

publishers of news and information.

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189. Defendants’ practice of generating misinformation and then wrongfully attributing

it to the Publishers damages the Publishers’ brands, credibility and reputation, and undermines the

Publishers’ investment, goodwill and reputation.

COUNT I: Copyright Infringement (17 U.S.C. § 501)

On Behalf of the Publishers Against All Defendants

190. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

191. The Publishers are the owners of the registered copyrights reflected in Exhibits A-

H. It is and has been since at least the mid-2000’s the business practice of the Publishers to publish

in electronic format on the Publishers’ respective websites every article that also appears in that

newspaper’s print edition. It has additionally been the business practice of some of the Publishers

to publish in electronic format on those Publishers’ respective websites articles from older print

editions of those newspapers. For example, the Chicago Tribune has issues dating back to March

1985 available on its website. All of the copyright registrations containing the Publishers’ Works

that are asserted as infringed are reflected on Exhibits A-H. (The Publishers reserve the right to

revise or supplement these exhibits if it becomes clear during discovery that additional registered

works of the Publishers were also copied by Plaintiffs.) The electronic versions of the articles are

substantially the same as their print-edition counterparts.

192. The electronic versions of the articles found in each of the Publishers’ Works set

forth in Exhibits A-H were copied to train Defendants’ GPT models and, in many cases, have been

distributed by and encoded within Defendants’ GPT models. As the owners of the registered

copyrights in the literary works that Defendants have copied, distributed, and encoded in

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Defendants’ GPT models, the Publishers hold the exclusive rights to those works under 17 U.S.C.

§ 106.

193. By illegally building training datasets containing the Publishers’ Works, including

by scraping copies of the Publishers’ Works from the Publishers’ websites and reproducing these

works from third-party datasets, Microsoft and the OpenAI Defendants have directly infringed the

Publishers’ exclusive rights in their copyrighted works.

194. By illegally storing, processing, and reproducing the training datasets containing

the Publishers’ Works to train the GPT models on Microsoft’s supercomputing platform, Microsoft

and the OpenAI Defendants have jointly directly infringed the Publishers’ exclusive rights in their

copyrighted works.

195. On information and belief, by storing, processing, and reproducing the GPT models

trained on the Publishers’ Works, which GPT models themselves have memorized, on Microsoft’s

supercomputing platform, Microsoft and the OpenAI Defendants have jointly directly infringed

the Publishers’ exclusive rights in their copyrighted works.

196. By disseminating generative output containing copies and derivatives of the

Publishers’ Works through the ChatGPT offerings, the OpenAI Defendants have directly infringed

the Publishers’ exclusive rights in their copyrighted works.

197. By disseminating generative output containing copies and derivatives of the

Publishers’ Works through the Copilot (formerly known as Bing Chat) offerings, Microsoft has

directly infringed the Publishers’ exclusive rights in their copyrighted works.

198. On information and belief, Defendants’ infringing conduct alleged herein was and

continues to be willful and carried out with full knowledge of the Publishers’ rights in their Works.

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As a direct result of their conduct, Defendants have wrongfully profited from copyrighted works

that they do not own.

199. By and through the actions alleged above, Defendants have infringed and will

continue to infringe the Publishers’ copyrights.

200. As a direct and proximate result of Defendants’ infringing conduct alleged herein,

the Publishers have sustained and will continue to sustain substantial, immediate, and irreparable

injury for which there is no adequate remedy at law. Unless Defendants’ infringing conduct is

enjoined by this Court, Defendants have demonstrated an intent to continue to infringe the

Publishers’ Works. The Publishers therefore are entitled to permanent injunctive relief restraining

and enjoining Defendants’ ongoing infringing conduct.

201. The Publishers are further entitled to recover statutory damages, actual damages,

restitution of profits, attorneys’ fees, and other remedies provided by law.

COUNT II: Vicarious Copyright Infringement

On Behalf of the Publishers Against Microsoft, OpenAI, Inc., OpenAI, GP, OpenAI LP,
OAI Corporation, LLC,
OpenAI Holdings, LLC, and OpenAI Global, LLC

202. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

203. Microsoft controlled, directed, and profited from the infringement perpetrated by

the OpenAI Defendants. Microsoft controls and directs the supercomputing platform used to store,

process, and reproduce the training datasets containing the Publishers’ Works, the GPT models,

and OpenAI’s ChatGPT offerings. Microsoft profited from the infringement perpetrated by the

OpenAI defendants by incorporating the infringing GPT models trained on the Publishers’ Works

into its own product offerings, including Copilot (formerly known as Bing Chat).

87
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204. Defendants OpenAI, Inc.; OpenAI, GP; OAI Corporation, LLC; OpenAI Holdings,

LLC; and Microsoft controlled, directed, and profited from the infringement perpetrated by

Defendants OpenAI LP; OpenAI Global, LLC; OpenAI OpCo, LLC; and OpenAI, LLC, including

the reproduction and distribution of the Publishers’ Works.

205. Defendants OpenAI Global, LLC and OpenAI LP directed, controlled, and profited

from the infringement perpetrated by Defendants OpenAI OpCo, LLC and OpenAI, LLC,

including the reproduction and distribution of the Publishers’ Works.

206. Defendants OpenAI, Inc.; OpenAI LP; OAI Corporation, LLC; OpenAI Holdings,

LLC; OpenAI Global, LLC; and Microsoft are vicariously liable for copyright infringement.

COUNT III: Contributory Copyright Infringement

On Behalf of the Publishers Against Microsoft

207. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

208. Microsoft materially contributed to and directly assisted in the direct infringement

attributable to the OpenAI Defendants.

209. Microsoft provided the supercomputing infrastructure and directly assisted the

OpenAI Defendants in: (i) building training datasets containing copies of the Publishers’ Works;

(ii) storing, processing, and reproducing the training datasets containing copies of the Publishers’

Works used to train the GPT models; and (iii) providing the computing resources to host, operate,

and commercialize the GPT models and GenAI products.

210. Microsoft knew or had reason to know of the direct infringement perpetrated by the

OpenAI Defendants because Microsoft and OpenAI’s partnership extends to the development,

commercialization, and monetization of the OpenAI Defendants’ GPT-based products. Microsoft

was fully aware of the capabilities of OpenAI’s GPT-based products.

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COUNT IV: Contributory Copyright Infringement

On Behalf of the Publishers Against All Defendants

211. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

212. In the alternative, to the extent an end-user may be liable as a direct infringer based

on the output of the GPT-based products, Defendants materially contributed to and directly assisted

with the direct infringement perpetrated by end-users of the GPT-based products by way of: (i)

jointly-developing LLM models capable of distributing unlicensed copies of the Publishers’ Works

to end-users; (ii) building and training the GPT LLMs using the Publishers’ Works; and (iii)

deciding what content is actually outputted by the GenAI products, such as grounding output in

the Publishers’ Works through retrieval augmented generation, fine-tuning the models for desired

outcomes, and/or selecting and weighting the parameters of the GPT LLMs.

213. On information and belief Defendants continue to maintain and support user

accounts that are used to retrieve infringing output from Defendants’ GPT-based products.

214. Defendants had either actual knowledge or constructive knowledge of the direct

infringement by end-users or were willfully blind to the direct infringement of end-users because:

(i) Defendants undertake extensive efforts in developing, testing, and troubleshooting their LLM

models and GPT-based products; (ii) Defendants programmed their systems to flag infringing

outputs and prompts seeking infringing output; (iii) Defendants have been repeatedly informed of

instances where their GPT-based products output infringing content to users and the capability of

their GPT-based models to produce infringing output has been the subject of public conversation;

(iv) Defendants are aware that at least some users use their GPT-based products for the purpose of

accessing copyrighted works; and (v) Defendants have publicly recognized and admitted that their

89
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GPT-based products are capable of distributing unlicensed copies of copyrighted works and

derivatives thereof.

COUNT V: Digital Millennium Copyright Act – Removal of Copyright Management


Information (17 U.S.C. § 1202)

On Behalf of the Publishers Against All Defendants

215. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

216. The Publishers included one or more forms of copyright-management information

in each of the Publishers’ Works, including: a copyright notice, authors’ names, publisher’s name,

title and other identifying information, terms and conditions of use, and identifying numbers or

symbols referring to the copyright-management information.

217. Without the Publishers’ authority, Defendants copied the Publishers’ Works and

used them as training data for their GenAI models.

218. On information and belief, Defendants removed the Publishers’ copyright-

management information in building the training datasets containing copies of the Publishers’

Works, including removing the Publishers’ copyright-management information from the

Publishers’ Works scraped directly from the Publishers’ websites and removing the Publishers’

copyright-management information from the Publishers’ Works reproduced from third-party

datasets.

219. On information and belief, Microsoft and OpenAI removed the Publishers’

copyright-management information through generating synthetic search results, including

removing the Publishers’ copyright-management information when scraping the Publishers’ Works

from the Publishers’ websites and generating copies or derivatives of the Publishers’ Works as

output for the Browse with Bing and Copilot (formerly known as Bing Chat) offerings.

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220. Microsoft and OpenAI removed the Publishers’ copyright-management

information in generating outputs from the GPT models containing copies or derivatives of the

Publishers’ Works.

221. By design, Defendants’ GPT-based products do not preserve any copyright-

management information, and the outputs of Defendants’ GPT models removed any copyright

notices, titles, and identifying information, despite the fact that those outputs were often verbatim

reproductions of the Publishers’ Works. Therefore, Defendants intentionally removed copyright-

management information from the Publishers’ Works in violation of 17 U.S.C. § 1202(b)(1).

222. Defendants’ removal or alteration of the Publishers’ copyright-management

information has been done knowingly and with the intent to induce, enable, facilitate, or conceal

Defendants’ or end-users’ infringement of the Publishers’ copyrights.

223. Without the Publishers’ authority, Defendants created copies and derivative works

based on the Publishers’ Works. By distributing these works without their copyright-management

information, Defendant violated 17 U.S.C. § 1202(b)(3).

224. Defendants knew or had reasonable grounds to know that their removal of

copyright-management information would facilitate copyright infringement by concealing the fact

that the GPT models are infringing copyrighted works and that outputs from the GPT models are

infringing copies and derivative works.

225. The Publishers have been injured by Defendants’ removal of copyright-

management information. The Publishers are entitled to statutory damages, actual damages,

restitution of profits, and other remedies provided by law, including full costs and attorneys’ fees.

91
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COUNT VI: Common Law Unfair Competition By Misappropriation

On Behalf of the Publishers Against All Defendants

226. The Publishers incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

227. The Publishers gather information, which often takes the form of time-sensitive

breaking news, for their content at a substantial cost to the Publishers, including the hundreds of

millions of dollars and countless “people hours” that the Publishers have spent in their commitment

to investigate and accurately report local news to local communities and distribute the paper in

print and digital forms.

228. By offering GenAI content that is the same as or similar to content published by the

Publishers, Defendants’ GenAI products directly compete with the Publishers’ content.

229. Defendants’ use of the Publishers’ content in the outputs of its GenAI products to

produce informative text of the same general type and kind that the Publishers produce competes

with the Publishers’ content for traffic.

230. Defendants’ use of the Publishers’ content without the Publishers’ consent

constitutes free-riding on the Publishers’ significant efforts and investment of human capital to

gather this information, by allowing Defendants to reap the benefits of providing the time-sensitive

content that had been gathered through the Publishers’ efforts.

231. Defendants’ misuse and misappropriation of the Publishers’ content has caused the

Publishers to suffer actual damages from the deprivation of the benefits of their work, such as,

without limitation, lost advertising and subscription revenue. It has also reduced the Publishers’

incentive to create such time-sensitive materials, because those materials can then be easily

reproduced by users of Defendants’ products with no accompanying benefit to the Publishers.

92
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232. By depriving the Publishers of the benefits of their work, Defendants’ misuse and

misappropriation of the Publishers’ content substantially threatens the quality of the Publishers’

content and disincentivizes the Publishers to produce their content, threatening their continued

viability.

COUNT VII: Trademark Dilution (15 U.S.C. § 1125(c))

On Behalf of Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News,
LLC; and DP Media Network, LLC Against All Defendants

233. Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News, LLC;

and DP Media Network, LLC incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

234. Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News, LLC;

and DP Media Network, LLC are the owners of several trademarks, including the federally

registered trademarks, set forth in Exhibit I (hereinafter referred to as the “Diluted Trademarks”).

235. The Diluted Trademarks are distinctive and “famous marks” within the meaning of

Section 43(c) of the Lanham Act, 15 U.S.C. § 1125(c) and are widely recognized by the general

consuming public of the United States.

236. The Diluted Trademarks became distinctive and famous prior to the Defendants’

unauthorized use of the Diluted Trademarks as alleged herein.

237. The Diluted Trademarks have been used in interstate commerce for decades, and

many for over one-hundred years.

238. The Daily News was founded in 1919 and was the first U.S. daily printed in tabloid

format. By 1947 it reached a circulation of 2.4 million copies a day. As of May 2016, it was the

ninth-most widely circulated daily newspaper in the United States, and has won 11 Pulitzer Prizes

93
Case 1:24-cv-03285 Document 1 Filed 04/30/24 Page 94 of 98

and has generated substantial revenue under its NEW YORK DAILY NEWS and registered

NYDAILYNEWS.COM brands.

239. The Chicago Tribune was founded in 1847 and by 2022, it had the seventh-highest

circulation of any American newspaper, has won 28 Pulitzer Prizes and has generated substantial

revenue under its CHICAGO TRIBUNE brand.

240. The San-Jose Mercury News was first published in 1851. As of March 2013, it was

the fifth most widely circulated daily newspaper in the United States. The Mercury News attracts

readers from across the United States. Time Magazine called The Mercury News branded

publication the most technologically savvy newspaper in the country, and the Mercury News has

generated substantial revenue under its THE MERCURY NEWS brand.

241. What is now The Denver Post was first formed in 1892. In 1895 it changed its name

to the Denver Evening Post, and then in 1901 it became The Denver Post, the name and brand it

has used for over one hundred years. The Denver Post attracts readers from across the United

States. In 2016, its website received roughly six million monthly unique visitors generating more

than 13 million page views. The Denver Post has won 9 Pulitzer Prizes among many other national

and local awards, and has generated substantial revenue under its THE DENVER POST brand.

242. Currently millions of consumers access the publications, either online or in print,

circulated under each of the Diluted Trademarks.

243. The Diluted Trademarks have been used in connection with the sale of goods and/or

services to the general public at large in all fifty states of the United States.

244. The Diluted Trademarks are used in connection with publications that are among

the most highly circulated in the United States.

94
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245. Each of the Diluted Trademarks has achieved household recognition through

millions of dollars of advertising and promotion across the United States and has achieved wide-

scale third party recognition and unsolicited media attention.

246. Defendants have, in connection with the commerce of producing GenAI to users

for profit throughout the United States, including in New York, engaged in the unauthorized use

of the Diluted Trademarks in branding outputs generated by Defendants’ GPT-based products.

247. Defendants’ unauthorized use of the Diluted Trademarks on lower-quality and

inaccurate writing dilutes the quality of the Diluted Trademarks by tarnishment, in violation of 15

U.S.C § 1125(c).

248. Defendants are aware that their GPT-based products produce inaccurate content that

is falsely attributed to the Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-

News, LLC; and DP Media Network, LLC, and yet continue to profit commercially from creating

and attributing inaccurate content to the Daily News, LP; Chicago Tribune Company, LLC; San

Jose Mercury-News, LLC; and DP Media Network, LLC. As such, Defendants have intentionally

violated 15 U.S.C § 1125(c).

249. As an actual and proximate result of the unauthorized use of the Diluted

Trademarks, the Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News,

LLC; and DP Media Network, LLC have suffered and continue to suffer harm by, among other

harms, harming their reputation for accuracy, originality, and quality, which has and will continue

to cause them economic loss.

95
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COUNT VIII: Dilution and Injury to Business Reputation (N.Y. Gen. Bus. Law § 360-l)

On Behalf of Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News,
LLC; and DP Media Network, LLC Against All Defendants

250. Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News, LLC;

and DP Media Network, LLC incorporate by reference and reallege the preceding allegations as

though fully set forth herein.

251. The Diluted Trademarks have a distinctive quality and have enjoyed such

distinctiveness since long before Defendants adopted and began the unauthorized use of the

Diluted Trademarks.

252. Defendants’ activities, as described above, dilute the distinctiveness of the Diluted

Trademarks, as well as injure the business reputation of the Daily News, LP; Chicago Tribune

Company, LLC; San Jose Mercury-News, LLC; and DP Media Network, LLC, all in violation of

their rights under New York General Business Law § 360-l.

253. Defendants are aware that their GPT-based products produce inaccurate content that

is falsely attributed to Daily News, LP; Chicago Tribune Company, LLC; San Jose Mercury-News,

LLC; and DP Media Network, LLC and yet continue to profit commercially from creating and

attributing inaccurate content to Daily News, LP; Chicago Tribune Company, LLC; San Jose

Mercury-News, LLC; and DP Media Network, LLC. As such, Defendants have intentionally

violated New York General Business Law § 360-l.

254. Defendants’ violations of N.Y. Gen. Bus. Law § 360-l, unless enjoined by this

Court, will continue to cause Daily News, LP; Chicago Tribune Company, LLC; San Jose

Mercury-News, LLC; and DP Media Network, LLC to sustain irreparable damage, loss and injury,

for which they have no adequate remedy at law.

96
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PRAYER FOR RELIEF

WHEREFORE, the Publishers demand judgment against each Defendant as follows:

255. Awarding the Publishers statutory damages, compensatory damages, restitution,

disgorgement, and any other relief that may be permitted by law or equity;

256. Permanently enjoining Defendants from the unlawful, unfair, and infringing

conduct alleged herein;

257. Ordering destruction under 17 U.S.C. § 503(b) of all GPT or other LLM models

and training sets that incorporate the Publishers’ Works;

258. An award of costs, expenses, and attorneys’ fees as permitted by law; and

259. Such other or further relief as the Court may deem appropriate, just, and equitable.

DEMAND FOR JURY TRIAL

The Publishers hereby demand a jury trial for all claims so triable.

Dated: April 30, 2024 By: /s/ Steven Leiberman

Steven Lieberman (SL8687)


Jennifer B. Maisel (5096995)
Robert Parker (pro hac vice forthcoming)
Jenny L. Colgate (pro hac vice forthcoming)
Kristen J. Logan (pro hac vice forthcoming)
Bryan B. Thompson (pro hac vice forthcoming)
ROTHWELL, FIGG, ERNST & MANBECK, P.C.
901 New York Avenue, N.W., Suite 900 East
Washington, DC 20001
Telephone: (202) 783-6040
Facsimile: (202) 783-6031
slieberman@rothwellfigg.com
jmaisel@rothwellfigg.com
rparker@rothwellfigg.com
jcolgate@rothwellfigg.com
klogan@rothwellfigg.com
bthompson@rothwellfigg.com

Jeffrey A. Lindenbaum (JL1971)


ROTHWELL, FIGG, ERNST & MANBECK, P.C.

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Case 1:24-cv-03285 Document 1 Filed 04/30/24 Page 98 of 98

The Holyoke-Manhattan Building


80 South Highland Avenue
Ossining, New York 10562
Telephone: (202) 783-6040
Facsimile: (202) 783-6031
jlindenbaum@rothwellfigg.com

Attorneys for Plaintiffs

98
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 1 of 8

EXHIBIT A
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 2 of 8

NEW YORK DAILY NEWS


Registration Date Issue Registered (Month/Year) Registration Number
01/11/1996 September 1995 TX0004181162
01/11/1996 October 1995 TX0004181146
02/27/1996 November 1995 TX0004184972
02/27/1996 December 1995 TX0004184973
04/23/1996 January 1996 TX0004211544
04/23/1996 February 1996 TX0004211543
07/02/1996 March 1996 TX0004356482
07/02/1996 April 1996 TX0004307866
09/18/1996 May 1996 TX0004336927
09/18/1996 June 1996 TX0004336926
11/04/1996 July 1996 TX0004356479
11/04/1996 August 1996 TX0004363177
01/13/1997 September 1996 TX0004434625
01/23/1997 October 1996 TX0004434628
03/10/1997 November 1996 TX0004420539
03/10/1997 December 1996 TX0004420538
04/16/1997 January 1997 TX0004439645
04/16/1997 February 1997 TX0004439651
06/19/1997 March 1997 TX0004490696
06/19/1997 April 1997 TX0004490694
09/10/1997 May 1997 TX0004544992
09/19/1997 July 1997 TX0004612229
09/19/1997 June 1997 TX0004544995
01/13/1998 August 1997 TX0004602997
02/05/1998 October 1997 TX0004903236
02/05/1998 November 1997 TX0004612362
04/01/1998 December 1997 TX0004661106
04/01/1998 January 1998 TX0004661105
06/25/1998 February 1998 TX0004740493
06/25/1998 March 1998 TX0004651211
06/25/1998 April 1998 TX0004651213
10/06/1998 May 1998 TX0004778979
10/06/1998 June 1998 TX0004770526
10/06/1998 July 1998 TX0004770527
12/22/1998 September 1998 TX0004858606
12/22/1998 August 1998 TX0004646816
02/11/1999 December 1998 TX0005392419
02/11/1999 October 1998 TX0004874119
02/11/1999 November 1998 TX0004874120
03/10/1999 January 1999 TX0004861644
06/07/1999 February 1999 TX0004919704
06/07/1999 March 1999 TX0004919712
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 3 of 8

08/23/1999 May 1999 TX0004054833


08/23/1999 June 1999 TX0004054842
09/28/1999 July 1999 TX0004054837
10/25/1999 July 1999 TX0004987124
10/25/1999 August 1999 TX0004987176
02/02/2000 October 1999 TX0005355288
02/02/2000 September 1999 TX0005041561
03/02/2000 December 1999 TX0005355289
03/02/2000 November 1999 TX0005062115
06/05/2000 March 2000 TX0005205479
06/05/2000 January 2000 TX0005132815
06/05/2000 February 2000 TX0005132814
08/24/2000 April 2000 TX0005340324
01/22/2001 October 2000 TX0005235707
01/22/2001 November 2000 TX0005235706
02/09/2001 September 2000 TX0005392420
02/09/2001 August 2000 TX0005274278
04/23/2001 December 2000 TX0005298887
04/23/2001 January 2001 TX0005298886
07/13/2001 May 2000 TX0005340325
07/13/2001 June 2000 TX0005340326
07/23/2001 February 2001 TX0005345262
07/23/2001 March 2001 TX0005345256
07/23/2001 March 2001 TX0005354862
08/20/2001 May 2001 TX0005369669
10/09/2001 July 2001 TX0005433229
10/09/2001 June 2001 TX0005532425
01/07/2002 September 2001 TX0005569849
02/11/2002 October 2001 TX0005569860
03/12/2002 November 2001 TX0005565366
04/08/2002 December 2001 TX0005562067
04/15/2002 January 2002 TX0005502726
05/23/2002 August 2001 TX0005651817
05/31/2002 March 2002 TX0005532052
07/03/2002 April 2002 TX0005599836
08/16/2002 May 2002 TX0005613116
09/10/2002 June 2002 TX0005809677
10/11/2002 July 2002 TX0005600427
10/11/2002 August 2002 TX0005600372
11/20/2002 September 2002 TX0005639685
01/07/2003 October 2002 TX0005654144
02/20/2003 December 2002 TX0005809658
03/03/2003 February 2002 TX0005807918
04/07/2003 January 2003 TX0005874446
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 4 of 8

04/22/2003 February 2003 TX0005808011


06/20/2003 April 2003 TX0005673138
06/23/2003 March 2003 TX0005673137
08/11/2003 May 2003 TX0005800527
09/10/2003 June 2003 TX0005806815
10/29/2003 July 2003 TX0005873983
11/10/2003 August 2003 TX0005873976
11/10/2003 September 2003 TX0005873981
01/09/2004 October 2003 TX0005873995
02/18/2004 November 2003 TX0005892621
02/18/2004 December 2003 TX0005892029
04/23/2004 January 2004 TX0005989264
06/21/2004 March 2004 TX0005985737
07/13/2004 April 2004 TX0005989263
07/30/2004 May 2004 TX0005996395
09/27/2004 June 2004 TX0006033163
10/12/2004 July 2004 TX0006069578
11/03/2004 August 2004 TX0006078193
12/06/2004 September 2004 TX0006078197
01/14/2005 October 2004 TX0006093680
03/04/2005 November 2004 TX0006163397
05/02/2005 January 2005 TX0006166840
05/09/2005 February 2005 TX0006166826
06/01/2005 March 2005 TX0006172142
08/10/2005 April 2005 TX0006206925
08/10/2005 May 2005 TX0006206938
09/13/2005 June 2005 TX0006222655
10/11/2005 July 2005 TX0006226328
11/08/2005 August 2005 TX0006332311
12/15/2005 September 2005 TX0006265651
12/19/2005 October 2005 TX0006265650
01/18/2006 November 2005 TX0006340725
03/20/2006 December 2005 TX0006313834
04/19/2006 January 2006 TX0006313848
05/08/2006 February 2006 TX0006379117
06/12/2006 March 2006 TX0006359046
07/24/2006 April 2006 TX0006422037
08/04/2006 May 2006 TX0006411133
08/06/2006 August 2006 TX0006461698
09/22/2006 June 2006 TX0006483222
10/10/2006 July 2006 TX0006436480
12/06/2006 September 2006 TX0006481156
01/10/2007 October 2006 TX0006511623
01/16/2007 November 2006 TX0006498507
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 5 of 8

03/05/2007 December 2006 TX0006550579


03/21/2007 January 2007 TX0006611867
05/03/2007 February 2007 TX0006614601
06/21/2007 March 2007 TX0006608052
07/10/2007 April 2007 TX0006608028
08/17/2007 May 2007 TX0006614530
09/13/2007 June 2007 TX0006630210
10/04/2007 July 2007 TX0006630464
10/29/2007 August 2007 TX0006630330
03/28/2008 September 2007 TX0006685294
11/28/2007 September 2007 TX0006644579
01/24/2008 October 2007 TX0006647439
01/29/2008 November 2007 TX0006647513
03/19/2008 December 2007 TX0006647470
04/08/2008 January 2008 TX0006662942
05/05/2008 February 2008 TX0006647382
09/18/2008 March 2008 TX0006661227
09/18/2008 April 2008 TX0006662390
07/31/2008 May 2008 TX0006662512
08/14/2008 June 2008 TX0006662612
09/26/2008 July 2008 TX0006660576
11/21/2008 August 2008 TX0006660489
12/11/2008 September 2008 TX0006665017
02/18/2009 October 2008 TX0006631870
06/01/2009 October 2008 TX0006679578
02/18/2009 November 2008 TX0006631868
02/25/2009 December 2008 TX0006664945
05/01/2009 January 2009 TX0006680128
05/01/2009 February 2009 TX0006631565
06/24/2009 March 2009 TX0006679377
07/07/2009 April 2009 TX0006683910
07/09/2009 May 2009 TX0006683856
08/19/2009 June 2009 TX0006687583
10/14/2009 July 2009 TX0006685634
10/14/2009 August 2009 TX0006700127
11/20/2009 September 2009 TX0006700088
01/14/2010 October 2009 TX0006701634
01/14/2010 November 2009 TX0006702359
03/29/2010 December 2009 TX0006702409
03/25/2010 January 2010 TX0006704073
06/03/2010 February 2010 TX0006704112
06/03/2010 March 2010 TX0006704111
10/04/2010 April 2010 TX0006772753
10/07/2010 May 2010 TX0006772759
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 6 of 8

02/10/2011 June 2010 TX0006772176


02/10/2011 July 2010 TX0006772172
02/10/2011 August 2010 TX0006772150
02/10/2011 September 2010 TX0006772151
04/29/2011 October 2010 TX0006776360
04/29/2011 November 2010 TX0006776361
06/03/2011 December 2010 TX0006776133
07/21/2011 January 2011 TX0006778793
07/21/2011 February 2011 TX0006779028
08/22/2011 March 2011 TX0006779078
08/22/2011 April 2011 TX0006779021
09/16/2011 May 2011 TX0006788057
09/29/2011 June 2011 TX0006573269
12/19/2011 July 2011 TX0006787848
03/22/2012 September 2011 TX0006789348
03/22/2012 October 2011 TX0006789350
03/30/2012 December 2011 TX0006604549
09/12/2012 March 2012 TX0006540595
09/12/2012 April 2012 TX0006540589
09/04/2013 September 2012 TX0007889332
09/04/2013 May 2012 TX0007900636
09/04/2013 March 2013 TX0007888497
09/04/2013 April 2013 TX0007888484
09/04/2013 February 2013 TX0007888461
09/04/2013 November 2012 TX0007889392
09/04/2013 July 2012 TX0007889303
09/04/2013 January 2013 TX0007889398
09/04/2013 October 2012 TX0007889363
09/04/2013 June 2012 TX0007889262
09/04/2013 August 2012 TX0007889287
09/04/2013 December 2012 TX0007900610
02/20/2014 July 2013 TX0007881783
02/20/2014 June 2013 TX0007881845
02/20/2014 October 2013 TX0007901938
02/20/2014 May 2013 TX0007881842
02/20/2014 September 2013 TX0007901983
02/20/2014 August 2013 TX0007901993
06/27/2014 November 2013 TX0007966225
06/27/2014 January 2014 TX0007966282
06/27/2014 December 2013 TX0007966172
11/13/2014 February 2014 TX0008072322
11/13/2014 March 2014 TX0008072328
11/13/2014 April 2014 TX0008072311
01/12/2015 May 2014 TX0008153354
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 7 of 8

01/12/2015 June 2014 TX0008153351


01/12/2015 July 2014 TX0008153376
05/20/2015 August 2014 TX0008153168
05/20/2015 September 2014 TX0008153172
05/20/2015 October 2014 TX0008180445
08/14/2015 November 2014 TX0008227386
08/14/2015 December 2014 TX0008227408
08/14/2015 January 2015 TX0008227404
10/26/2015 February 2015 TX0008231472
10/26/2015 April 2015 TX0008231486
10/26/2015 March 2015 TX0008231481
01/19/2016 June 2015 TX0008381791
01/19/2016 May 2015 TX0008203171
01/19/2016 July 2015 TX0008216172
10/24/2016 June 2016 TX0008408600
10/24/2016 July 2016 TX0008408601
10/24/2016 April 2016 TX0008408596
10/24/2016 May 2016 TX0008408597
10/24/2016 March 2016 TX0008408595
10/24/2016 February 2016 TX0008408589
11/20/2017 October 2015 TX0008608223
11/20/2017 November 2016 TX0008475846
11/20/2017 August 2015 TX0008608215
11/20/2017 September 2015 TX0008608219
11/20/2017 December 2015 TX0008608241
11/20/2017 December 2016 TX0008475852
11/20/2017 January 2017 TX0008475817
11/20/2017 November 2015 TX0008608230
11/20/2017 January 2016 TX0008608250
12/12/2017 April 2017 TX0008492681
12/12/2017 May 2017 TX0008492671
12/12/2017 July 2017 TX0008492604
12/12/2017 March 2017 TX0008492744
12/12/2017 June 2017 TX0008492709
12/12/2017 February 2017 TX0008492657
02/20/2018 November 2017 TX0008513597
02/20/2018 September 2017 TX0008513551
02/20/2018 August 2017 TX0008513535
02/20/2018 October 2017 TX0008513574
04/26/2018 January 2018 TX0008636405
05/15/2018 February 2018 TX0008634899
06/15/2018 March 2018 TX0008587215
09/19/2019 June 2019 TX0008849349
09/25/2019 August 2019 TX0008850490
Case 1:24-cv-03285 Document 1-1 Filed 04/30/24 Page 8 of 8

11/05/2019 October 2019 TX0008851950


12/11/2019 July 2019 TX0008850204
12/18/2019 November 2019 TX0008860520
01/10/2020 December 2019 TX0008851340
01/30/2020 August 2018 TX0008852401
04/23/2020 February 2020 TX0008878033
04/23/2020 January 2020 TX0008876594
05/06/2020 April 2020 TX0008875372
06/04/2020 May 2020 TX0008884591
06/10/2020 March 2020 TX0008883820
07/07/2020 June 2020 TX0008886680
08/12/2020 July 2020 TX0008894743
09/02/2020 August 2020 TX0008900611
10/08/2020 September 2020 TX0008914498
12/16/2020 October 2020 TX0008926202
01/04/2021 December 2020 TX0009198394
02/02/2021 January 2021 TX0008940858
02/09/2021 November 2020 TX0008935243
05/24/2021 March 2021 TX0008977857
08/27/2021 May 2021 TX0009007302
09/01/2021 August 2021 TX0009024689
10/08/2021 September 2021 TX0009077039
11/04/2021 October 2021 TX0009090067
12/10/2021 December 2021 TX0009122060
03/02/2022 February 2022 TX0009283686
06/06/2022 March 2022 TX0009163347
06/06/2022 May 2022 TX0009162678
06/06/2022 April 2022 TX0009163521
07/18/2022 June 2022 TX0009283689
08/30/2022 July 2022 TX0009213104
09/01/2022 August 2022 TX0009203092
02/10/2023 November 2022 TX0009272461
05/12/2023 April 2023 TX0009288782
05/24/2023 October 2022 TX0009266122
05/24/2023 September 2022 TX0009281621
06/08/2023 December 2022 TX0009272154
06/08/2023 January 2023 TX0009272146
08/17/2023 June 2023 TX0009326979
08/17/2023 May 2023 TX0009306433
09/22/2023 August 2023 TX0009342088
12/04/2023 November 2023 TX0009344955
12/04/2023 October 2023 TX0009344957
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 1 of 75

EXHIBIT B
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 2 of 75

CHICAGO TRIBUNE
Registration Date Issue Registered (Month/Year) Registration Number
03/06/1985 January 01 1985 TX0001524163
03/06/1985 January 02 1985 TX0001524203
03/06/1985 January 03 1985 TX0001524207
03/06/1985 January 04 1985 TX0001524206
03/06/1985 January 05 1985 TX0001524197
03/06/1985 January 06 1985 TX0001524167
03/06/1985 January 07 1985 TX0001524191
03/06/1985 January 08 1985 TX0001524200
03/06/1985 January 09 1985 TX0001524164
03/06/1985 January 10 1985 TX0001524205
03/06/1985 January 11 1985 TX0001524231
03/06/1985 January 12 1985 TX0001524232
03/06/1985 January 13 1985 TX0001524233
03/06/1985 January 14 1985 TX0001524189
03/06/1985 January 15 1985 TX0001524208
03/06/1985 January 16 1985 TX0001524160
03/06/1985 January 17 1985 TX0001524187
03/06/1985 January 19 1985 TX0001524190
03/06/1985 January 20 1985 TX0001524166
03/06/1985 January 21 1985 TX0001524204
03/06/1985 January 22 1985 TX0001524188
03/06/1985 January 23 1985 TX0001524158
03/06/1985 January 24 1985 TX0001524202
03/06/1985 January 25 1985 TX0001524199
03/06/1985 January 28 1985 TX0001524198
03/06/1985 January 29 1985 TX0001524201
03/06/1985 January 30 1985 TX0001524161
03/06/1985 January 31 1985 TX0001524162
03/06/1985 February 01 1985 TX0001524159
03/06/1985 February 02 1985 TX0001524186
03/05/1985 February 03 1985 TX0001514201
03/05/1985 February 05 1985 TX0001514200
03/05/1985 February 06 1985 TX0001514155
03/05/1985 February 07 1985 TX0001514154
03/05/1985 February 10 1985 TX0001514158
03/05/1985 February 11 1985 TX0001514170
03/05/1985 February 12 1985 TX0001514169
03/05/1985 February 13 1985 TX0001514168
03/05/1985 February 14 1985 TX0001514171
03/05/1985 February 15 1985 TX0001514172
03/27/1985 February 18 1985 TX0001556364
03/28/1985 February 19 1985 TX0001554636
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 3 of 75

03/27/1985 February 20 1985 TX0001554630


03/28/1985 February 21 1985 TX0001554637
03/28/1985 February 22 1985 TX0001556363
03/28/1985 February 23 1985 TX0001547119
04/04/1985 February 24 1985 TX0001556369
03/28/1985 February 25 1985 TX0001554638
03/27/1985 February 26 1985 TX0001536221
03/27/1985 February 27 1985 TX0001536220
03/27/1985 February 28 1985 TX0001536222
04/05/1985 March 01 1985 TX0001548818
05/10/1985 March 03 1985 TX0001566570
04/05/1985 March 05 1985 TX0001548823
04/05/1985 March 06 1985 TX0001554615
04/05/1985 March 07 1985 TX0001548816
04/05/1985 March 08 1985 TX0001548795
04/05/1985 March 12 1985 TX0001548802
04/05/1985 March 13 1985 TX0001548803
04/08/1985 March 14 1985 TX0001548771
04/09/1985 March 15 1985 TX0001559690
04/09/1985 March 18 1985 TX0001544623
04/09/1985 March 19 1985 TX0001544638
04/05/1985 March 20 1985 TX0001548824
04/05/1985 March 21 1985 TX0001554616
04/05/1985 March 22 1985 TX0001548799
04/05/1985 March 24 1985 TX0001548817
04/05/1985 March 25 1985 TX0001548821
04/05/1985 March 26 1985 TX0001548801
04/05/1985 March 27 1985 TX0001548804
05/10/1985 March 28 1985 TX0001566532
05/10/1985 March 29 1985 TX0001566572
05/10/1985 March 30 1985 TX0001566571
05/10/1985 March 31 1985 TX0001566573
06/20/1985 April 01 1985 TX0001592376
06/20/1985 April 02 1985 TX0001592377
06/20/1985 April 03 1985 TX0001592381
06/20/1985 April 04 1985 TX0001592375
06/20/1985 April 05 1985 TX0001592380
06/20/1985 April 06 1985 TX0001592374
06/20/1985 April 07 1985 TX0001592379
06/20/1985 April 08 1985 TX0001592378
06/20/1985 April 09 1985 TX0001592382
06/20/1985 April 10 1985 TX0001592373
06/20/1985 April 11 1985 TX0001592372
06/19/1985 April 14 1985 TX0001597145
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 4 of 75

06/19/1985 April 16 1985 TX0001597128


06/19/1985 April 18 1985 TX0001597127
06/19/1985 April 23 1985 TX0001631045
06/20/1985 April 26 1985 TX0001597135
06/20/1985 April 27 1985 TX0001597133
06/20/1985 April 28 1985 TX0001597136
06/20/1985 April 29 1985 TX0001597131
06/20/1985 April 30 1985 TX0001597130
06/20/1985 May 01 1985 TX0001597134
06/20/1985 May 02 1985 TX0001597129
06/20/1985 May 03 1985 TX0001597132
10/11/1985 May 06 1985 TX0001670272
10/11/1985 May 07 1985 TX0001670270
10/11/1985 May 08 1985 TX0001670269
10/11/1985 May 09 1985 TX0001670422
10/11/1985 May 10 1985 TX0001680622
11/26/1985 May 11 1985 TX0001713216
10/11/1985 May 12 1985 TX0001679373
11/26/1985 May 13 1985 TX0001713217
10/11/1985 May 14 1985 TX0001670348
10/11/1985 May 15 1985 TX0001670273
10/15/1985 May 16 1985 TX0001670257
10/15/1985 May 17 1985 TX0001679221
10/15/1985 May 18 1985 TX0001679203
10/15/1985 May 19 1985 TX0001670268
10/15/1985 May 20 1985 TX0001670256
10/15/1985 May 21 1985 TX0001670261
10/15/1985 May 22 1985 TX0001670246
10/15/1985 May 23 1985 TX0001679210
10/15/1985 May 24 1985 TX0001670255
10/15/1985 May 25 1985 TX0001679056
11/26/1985 May 27 1985 TX0001713218
10/15/1985 May 28 1985 TX0001670260
10/15/1985 May 29 1985 TX0001670259
10/15/1985 May 30 1985 TX0001670258
10/11/1985 May 31 1985 TX0001670347
11/26/1985 June 01 1985 TX0001713219
10/11/1985 June 02 1985 TX0001679374
10/11/1985 June 03 1985 TX0001670271
10/11/1985 June 04 1985 TX0001670349
10/16/1985 June 05 1985 TX0001669386
10/16/1985 June 06 1985 TX0001669387
10/16/1985 June 07 1985 TX0001669388
11/26/1985 June 09 1985 TX0001713245
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 5 of 75

10/16/1985 June 10 1985 TX0001669389


10/16/1985 June 11 1985 TX0001669390
10/16/1985 June 12 1985 TX0001669391
10/16/1985 June 13 1985 TX0001669392
10/16/1985 June 14 1985 TX0001677683
11/26/1985 June 15 1985 TX0001713246
10/11/1985 June 16 1985 TX0001670418
10/11/1985 June 17 1985 TX0001670419
10/16/1985 June 18 1985 TX0001671020
10/16/1985 June 19 1985 TX0001669383
10/16/1985 June 20 1985 TX0001669384
10/16/1985 June 21 1985 TX0001669385
11/26/1985 June 22 1985 TX0001713247
10/11/1985 June 23 1985 TX0001670424
10/11/1985 June 24 1985 TX0001669241
11/26/1985 June 25 1985 TX0001699463
10/11/1985 June 26 1985 TX0001669242
10/11/1985 June 27 1985 TX0001669243
10/11/1985 June 28 1985 TX0001670344
10/11/1985 June 29 1985 TX0001670345
10/11/1985 June 30 1985 TX0001669240
10/11/1985 July 01 1985 TX0001670242
10/11/1985 July 02 1985 TX0001670346
10/11/1985 July 03 1985 TX0001670249
11/26/1985 July 04 1985 TX0001699475
11/26/1985 July 05 1985 TX0001713248
11/26/1985 July 06 1985 TX0001699476
10/11/1985 July 07 1985 TX0001670423
10/09/1985 July 08 1985 TX0001664172
10/09/1985 July 09 1985 TX0001664171
10/09/1985 July 10 1985 TX0001664170
10/09/1985 July 11 1985 TX0001664162
10/09/1985 July 12 1985 TX0001664174
11/26/1985 July 13 1985 TX0001713249
10/09/1985 July 14 1985 TX0001664173
10/09/1985 July 16 1985 TX0001664169
10/09/1985 July 17 1985 TX0001664168
10/09/1985 July 18 1985 TX0001664163
10/09/1985 July 19 1985 TX0001666452
11/26/1985 July 20 1985 TX0001699472
10/09/1985 July 21 1985 TX0001664166
10/09/1985 July 22 1985 TX0001664165
10/09/1985 July 23 1985 TX0001664164
10/09/1985 July 24 1985 TX0001664167
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 6 of 75

10/09/1985 July 25 1985 TX0001666453


11/26/1985 July 26 1985 TX0001699461
11/26/1985 July 27 1985 TX0001699462
11/26/1985 July 28 1985 TX0001699473
10/10/1985 July 29 1985 TX0001670339
10/10/1985 July 30 1985 TX0001679216
10/10/1985 July 31 1985 TX0001679215
10/10/1985 August 01 1985 TX0001679217
10/10/1985 August 02 1985 TX0001679218
10/10/1985 August 04 1985 TX0001670416
10/10/1985 August 05 1985 TX0001670250
10/10/1985 August 06 1985 TX0001670233
10/10/1985 August 07 1985 TX0001670226
10/10/1985 August 08 1985 TX0001670232
10/10/1985 August 09 1985 TX0001670234
10/15/1985 August 12 1985 TX0001669294
10/15/1985 August 13 1985 TX0001669250
10/15/1985 August 14 1985 TX0001669252
10/15/1985 August 15 1985 TX0001669253
10/15/1985 August 16 1985 TX0001670243
10/15/1985 August 19 1985 TX0001669251
10/15/1985 August 20 1985 TX0001669246
08/15/1985 August 21 1985 TX0001669295
10/15/1985 August 22 1985 TX0001669248
10/15/1985 August 23 1985 TX0001669247
10/15/1985 August 25 1985 TX0001669249
10/10/1985 August 26 1985 TX0001677674
10/10/1985 August 27 1985 TX0001677675
10/10/1985 August 28 1985 TX0001677676
10/10/1985 August 29 1985 TX0001677671
10/10/1985 August 30 1985 TX0001677670
10/10/1985 August 31 1985 TX0001677678
10/10/1985 September 03 1985 TX0001677677
10/10/1985 September 04 1985 TX0001677679
10/10/1985 September 05 1985 TX0001677680
10/10/1985 September 07 1985 TX0001677681
10/10/1985 September 09 1985 TX0001677682
10/10/1985 September 10 1985 TX0001677664
10/10/1985 September 11 1985 TX0001677668
10/10/1985 September 12 1985 TX0001677669
10/11/1985 September 13 1985 TX0001680623
10/11/1985 September 16 1985 TX0001671919
10/11/1985 September 17 1985 TX0001671920
10/11/1985 September 18 1985 TX0001679371
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 7 of 75

10/11/1985 September 19 1985 TX0001679370


10/11/1985 September 20 1985 TX0001679372
10/11/1985 September 22 1985 TX0001671921
10/15/1985 September 23 1985 TX0001677688
10/15/1985 September 24 1985 TX0001677687
10/15/1985 September 25 1985 TX0001677686
10/15/1985 September 27 1985 TX0001671854
10/15/1985 September 29 1985 TX0001677685
10/15/1985 September 30 1985 TX0001671853
10/15/1985 October 01 1985 TX0001680717
01/27/1986 October 02 1985 TX0001747681
01/27/1986 October 03 1985 TX0001748004
01/27/1986 October 04 1985 TX0001747596
01/27/1986 October 05 1985 TX0001748064
01/27/1986 October 06 1985 TX0001747682
01/27/1986 October 07 1985 TX0001747985
01/27/1986 October 08 1985 TX0001747986
01/27/1986 October 09 1985 TX0001747593
01/27/1986 October 10 1985 TX0001747683
01/27/1986 October 11 1985 TX0001747987
01/27/1986 October 12 1985 TX0001748003
01/27/1986 October 13 1985 TX0001747976
01/27/1986 October 14 1985 TX0001805137
01/27/1986 October 15 1985 TX0001747326
01/27/1986 October 16 1985 TX0001747589
01/27/1986 October 17 1985 TX0001747967
01/27/1986 October 18 1985 TX0001747712
01/27/1986 October 19 1985 TX0001747970
01/27/1986 October 20 1985 TX0001748105
01/27/1986 October 21 1985 TX0001747988
01/27/1986 October 22 1985 TX0001748002
01/27/1986 October 23 1985 TX0001748000
01/27/1986 October 24 1985 TX0001747595
01/31/1986 October 25 1985 TX0001746089
01/31/1986 October 26 1985 TX0001747247
01/31/1986 October 27 1985 TX0001747246
01/31/1986 October 28 1985 TX0001747249
01/31/1986 October 29 1985 TX0001746088
01/31/1986 October 30 1985 TX0001746087
01/31/1986 October 31 1985 TX0001746052
02/05/1986 November 01 1985 TX0001746795
01/31/1986 November 02 1985 TX0001746085
01/31/1986 November 03 1985 TX0001746086
01/27/1986 November 04 1985 TX0001747594
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 8 of 75

01/27/1986 November 05 1985 TX0001747331


01/27/1986 November 06 1985 TX0001747324
01/27/1986 November 07 1985 TX0001747588
01/27/1986 November 08 1985 TX0001747999
01/27/1986 November 10 1985 TX0001747971
01/27/1986 November 11 1985 TX0001747327
01/27/1986 November 12 1985 TX0001747966
01/27/1986 November 13 1985 TX0001747590
01/27/1986 November 14 1985 TX0001747965
01/27/1986 November 15 1985 TX0001748005
01/27/1986 November 16 1985 TX0001748001
01/27/1986 November 17 1985 TX0001748104
01/29/1986 November 18 1985 TX0001746392
01/29/1986 November 19 1985 TX0001746393
01/29/1986 November 20 1985 TX0001746375
01/29/1986 November 21 1985 TX0001746090
01/29/1986 November 22 1985 TX0001746391
02/05/1986 November 23 1985 TX0001746807
01/29/1986 November 24 1985 TX0001746051
02/05/1986 November 25 1985 TX0001746791
01/27/1986 November 26 1985 TX0001747968
01/27/1986 November 27 1985 TX0001747969
02/05/1986 November 28 1985 TX0001746805
01/27/1986 November 29 1985 TX0001747964
01/27/1986 November 30 1985 TX0001747325
01/27/1986 December 01 1985 TX0001747328
01/27/1986 December 02 1985 TX0001748171
01/22/1986 December 03 1985 TX0001737621
01/22/1986 December 04 1985 TX0001737619
01/22/1986 December 05 1985 TX0001747655
01/22/1986 December 06 1985 TX0001737620
01/22/1986 December 07 1985 TX0001737618
01/22/1986 December 08 1985 TX0001737617
01/22/1986 December 09 1985 TX0001737616
01/22/1986 December 10 1985 TX0001761713
01/17/1986 December 11 1985 TX0001740883
01/17/1986 December 12 1985 TX0001747674
01/17/1986 December 13 1985 TX0001740901
01/17/1986 December 14 1985 TX0001735629
01/17/1986 December 15 1985 TX0001735631
01/27/1986 December 16 1985 TX0001747330
01/27/1986 December 17 1985 TX0001747579
01/17/1986 December 18 1985 TX0001740884
01/27/1986 December 19 1985 TX0001747329
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 9 of 75

01/27/1986 December 20 1985 TX0001747592


01/27/1986 December 21 1985 TX0001747591
02/25/1986 December 22 1985 TX0001825502
02/25/1986 December 23 1985 TX0001825604
02/25/1986 December 24 1985 TX0001825600
02/25/1986 December 25 1985 TX0001825599
02/25/1986 December 26 1985 TX0001825500
02/25/1986 December 27 1985 TX0001765859
02/24/1986 December 28 1985 TX0001825607
02/24/1986 December 29 1985 TX0001825605
02/24/1986 December 30 1985 TX0001825606
01/17/1986 January 01 1986 TX0001764091
01/17/1986 January 02 1986 TX0001747648
01/17/1986 January 03 1986 TX0001747645
02/05/1986 January 04 1986 TX0001746806
01/17/1986 January 05 1986 TX0001747642
01/31/1986 January 06 1986 TX0001748143
01/31/1986 January 07 1986 TX0001748135
01/31/1986 January 08 1986 TX0001748134
01/17/1986 January 09 1986 TX0001747649
01/17/1986 January 10 1986 TX0001735636
01/17/1986 January 11 1986 TX0001735627
01/17/1986 January 12 1986 TX0001735630
01/17/1986 January 13 1986 TX0001735635
01/31/1986 January 14 1986 TX0001748133
01/31/1986 January 15 1986 TX0001746394
01/31/1986 January 16 1986 TX0001748136
01/31/1986 January 17 1986 TX0001748145
01/31/1986 January 18 1986 TX0001748144
01/31/1986 January 19 1986 TX0001748129
01/31/1986 January 20 1986 TX0001748137
02/03/1986 January 21 1986 TX0001764029
02/03/1986 January 22 1986 TX0001764025
02/03/1986 January 23 1986 TX0001764030
02/03/1986 January 24 1986 TX0001764027
02/03/1986 January 25 1986 TX0001764028
02/03/1986 January 26 1986 TX0001764026
02/11/1986 January 27 1986 TX0001764095
02/11/1986 January 28 1986 TX0001764096
02/11/1986 January 29 1986 TX0001764097
02/11/1986 January 30 1986 TX0001746866
02/11/1986 January 31 1986 TX0001764094
02/13/1986 February 01 1986 TX0001780483
02/13/1986 February 02 1986 TX0001780479
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 10 of 75

02/13/1986 February 03 1986 TX0001780482


02/13/1986 February 04 1986 TX0001780480
02/13/1986 February 05 1986 TX0001780481
02/13/1986 February 06 1986 TX0001873737
02/13/1986 February 07 1986 TX0001780485
02/13/1986 February 08 1986 TX0001780478
02/13/1986 February 09 1986 TX0001780486
02/13/1986 February 10 1986 TX0001780484
02/25/1986 February 11 1986 TX0001825603
02/25/1986 February 12 1986 TX0001825602
02/25/1986 February 13 1986 TX0001765857
02/25/1986 February 14 1986 TX0001765858
02/25/1986 February 15 1986 TX0001765860
02/25/1986 February 16 1986 TX0001765861
02/25/1986 February 17 1986 TX0001825601
03/03/1986 February 18 1986 TX0001767773
03/03/1986 February 19 1986 TX0001767730
02/24/1986 February 20 1986 TX0001825608
03/03/1986 February 21 1986 TX0001767771
03/03/1986 February 22 1986 TX0001767772
03/03/1986 February 23 1986 TX0001767775
03/10/1986 February 24 1986 TX0001767712
03/03/1986 February 25 1986 TX0001767741
03/10/1986 February 26 1986 TX0001767713
03/10/1986 February 27 1986 TX0001770793
03/10/1986 February 28 1986 TX0001767714
03/10/1986 March 01 1986 TX0001770791
03/10/1986 March 02 1986 TX0001770792
03/13/1986 March 03 1986 TX0001775284
03/13/1986 March 04 1986 TX0001775285
03/13/1986 March 05 1986 TX0001771823
03/13/1986 March 06 1986 TX0001771824
03/13/1986 March 07 1986 TX0001771825
03/13/1986 March 08 1986 TX0001771826
03/13/1986 March 09 1986 TX0001771819
03/25/1986 March 10 1986 TX0001837741
03/25/1986 March 11 1986 TX0001837743
03/25/1986 March 12 1986 TX0001899799
03/25/1986 March 13 1986 TX0001837742
03/25/1986 March 14 1986 TX0001802820
03/25/1986 March 15 1986 TX0001837740
03/25/1986 March 16 1986 TX0001821752
03/31/1986 March 18 1986 TX0001780448
03/31/1986 March 19 1986 TX0001778975
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 11 of 75

03/31/1986 March 20 1986 TX0001780447


03/31/1986 March 21 1986 TX0001780445
03/31/1986 March 22 1986 TX0001780446
03/31/1986 March 23 1986 TX0001778983
04/07/1986 March 24 1986 TX0001814757
04/07/1986 March 25 1986 TX0001805277
04/07/1986 March 26 1986 TX0001805273
04/07/1986 March 27 1986 TX0001805274
04/07/1986 March 28 1986 TX0001809602
04/07/1986 March 29 1986 TX0001805275
04/07/1986 March 30 1986 TX0001805276
04/25/1986 March 31 1986 TX0001807853
04/25/1986 April 01 1986 TX0001807856
04/25/1986 April 02 1986 TX0001807857
04/25/1986 April 03 1986 TX0001807858
04/25/1986 April 04 1986 TX0001818415
04/25/1986 April 05 1986 TX0001807852
04/25/1986 April 06 1986 TX0001809264
04/22/1986 April 07 1986 TX0001802228
04/22/1986 April 08 1986 TX0001802266
04/22/1986 April 09 1986 TX0001802267
04/02/1986 April 10 1986 TX0001802268
04/22/1986 April 11 1986 TX0001802294
04/22/1986 April 12 1986 TX0001842303
04/22/1986 April 13 1986 TX0001802293
04/29/1986 April 14 1986 TX0001797473
04/29/1986 April 15 1986 TX0001797472
04/29/1986 April 16 1986 TX0001797494
05/21/1986 April 17 1986 TX0001825356
04/29/1986 April 18 1986 TX0001797496
05/22/1986 April 19 1986 TX0001818417
04/29/1986 April 20 1986 TX0001797464
05/06/1986 April 21 1986 TX0001821785
05/06/1986 April 22 1986 TX0001821732
05/06/1986 April 23 1986 TX0001821733
05/06/1986 April 24 1986 TX0001816704
05/06/1986 April 25 1986 TX0001816705
05/06/1986 April 26 1986 TX0001816706
05/06/1986 April 27 1986 TX0001821722
05/09/1986 April 28 1986 TX0001816411
05/09/1986 April 29 1986 TX0001809678
05/09/1986 April 30 1986 TX0001816419
05/09/1986 May 01 1986 TX0001816418
05/09/1986 May 02 1986 TX0001816417
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 12 of 75

05/09/1986 May 03 1986 TX0001816410


05/09/1986 May 04 1986 TX0001816408
05/15/1986 May 05 1986 TX0001815157
05/15/1986 May 06 1986 TX0001815158
05/15/1986 May 07 1986 TX0001815159
05/15/1986 May 08 1986 TX0001815160
05/15/1986 May 09 1986 TX0001809658
05/15/1986 May 10 1986 TX0001809659
05/15/1986 May 11 1986 TX0001809518
05/28/1986 May 12 1986 TX0001825398
05/28/1986 May 13 1986 TX0001825375
05/28/1986 May 14 1986 TX0001825380
05/28/1986 May 15 1986 TX0001816697
05/28/1986 May 16 1986 TX0001825400
05/28/1986 May 17 1986 TX0001825399
05/28/1986 May 18 1986 TX0001816633
06/02/1986 May 19 1986 TX0001833448
06/02/1986 May 20 1986 TX0001833447
06/02/1986 May 21 1986 TX0001833441
06/02/1986 May 22 1986 TX0001833452
06/02/1986 May 23 1986 TX0001833451
06/02/1986 May 24 1986 TX0001833450
06/02/1986 May 25 1986 TX0001833449
06/09/1986 May 26 1986 TX0001834544
06/09/1986 May 27 1986 TX0001834542
06/09/1986 May 28 1986 TX0001834543
06/09/1986 May 29 1986 TX0001834545
06/09/1986 May 30 1986 TX0001834546
06/09/1986 May 31 1986 TX0001834537
06/09/1986 June 01 1986 TX0001834538
06/16/1986 June 02 1986 TX0001834558
06/16/1986 June 03 1986 TX0001836815
06/16/1986 June 04 1986 TX0001836814
06/16/1986 June 05 1986 TX0001836813
06/16/1986 June 06 1986 TX0001836821
06/16/1986 June 07 1986 TX0001836874
06/16/1986 June 08 1986 TX0001836875
06/23/1986 June 09 1986 TX0001833372
06/23/1986 June 10 1986 TX0001833375
06/23/1986 June 11 1986 TX0001833376
06/23/1986 June 12 1986 TX0001833374
06/23/1986 June 13 1986 TX0001833373
06/23/1986 June 14 1986 TX0001833431
06/23/1986 June 15 1986 TX0001833432
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 13 of 75

07/01/1986 June 16 1986 TX0001853202


07/01/1986 June 17 1986 TX0001853210
07/01/1986 June 18 1986 TX0001877474
07/01/1986 June 19 1986 TX0001877473
07/01/1986 June 20 1986 TX0001853209
07/01/1986 June 21 1986 TX0001852816
07/01/1986 June 22 1986 TX0001853214
07/07/1986 June 23 1986 TX0001852810
07/07/1986 June 24 1986 TX0001852809
07/07/1986 June 25 1986 TX0001852748
07/07/1986 June 26 1986 TX0001852761
07/07/1986 June 27 1986 TX0001852760
07/07/1986 June 28 1986 TX0001852841
07/07/1986 June 29 1986 TX0001852806
07/15/1986 June 30 1986 TX0001866292
07/15/1986 July 01 1986 TX0001866291
07/15/1986 July 02 1986 TX0001866318
07/15/1986 July 03 1986 TX0001866293
07/15/1986 July 04 1986 TX0001866294
07/15/1986 July 05 1986 TX0001866295
07/15/1986 July 06 1986 TX0001866317
07/18/1986 July 07 1986 TX0001880517
07/18/1986 July 08 1986 TX0001880518
07/18/1986 July 09 1986 TX0001873795
07/18/1986 July 10 1986 TX0001873802
07/18/1986 July 11 1986 TX0001873797
07/18/1986 July 12 1986 TX0001873798
07/18/1986 July 13 1986 TX0001873803
07/28/1986 July 14 1986 TX0001868793
07/28/1986 July 15 1986 TX0001868798
07/28/1986 July 16 1986 TX0001868794
07/28/1986 July 17 1986 TX0001868796
07/28/1986 July 18 1986 TX0001873977
07/28/1986 July 19 1986 TX0001868792
07/28/1986 July 20 1986 TX0001868795
08/04/1986 July 21 1986 TX0001886151
08/04/1986 July 22 1986 TX0001886150
08/04/1986 July 23 1986 TX0001886152
08/04/1986 July 24 1986 TX0001886153
08/04/1986 July 25 1986 TX0001886154
08/04/1986 July 26 1986 TX0001886155
08/04/1986 July 27 1986 TX0001886157
08/11/1986 July 28 1986 TX0001887668
08/11/1986 July 29 1986 TX0001887687
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 14 of 75

08/11/1986 July 30 1986 TX0001887686


08/11/1986 July 31 1986 TX0001887690
08/11/1986 August 01 1986 TX0001887689
08/11/1986 August 02 1986 TX0001887688
08/11/1986 August 03 1986 TX0001896346
08/18/1986 August 04 1986 TX0001880491
08/18/1986 August 05 1986 TX0001880492
08/18/1986 August 06 1986 TX0001880493
08/18/1986 August 07 1986 TX0001880567
08/18/1986 August 08 1986 TX0001880566
08/18/1986 August 09 1986 TX0001880565
08/18/1986 August 10 1986 TX0001892651
08/21/1986 August 11 1986 TX0001889078
08/21/1986 August 12 1986 TX0001890630
08/21/1986 August 13 1986 TX0001890629
08/21/1986 August 14 1986 TX0001880619
08/21/1986 August 15 1986 TX0001889082
08/21/1986 August 16 1986 TX0001889079
08/21/1986 August 17 1986 TX0001880644
09/08/1986 August 18 1986 TX0001900252
09/08/1986 August 19 1986 TX0001900255
09/08/1986 August 20 1986 TX0001900254
09/08/1986 August 21 1986 TX0001900253
09/08/1986 August 22 1986 TX0001900257
09/08/1986 August 23 1986 TX0001900256
09/08/1986 August 24 1986 TX0001900251
09/09/1986 August 25 1986 TX0001896405
09/09/1986 August 26 1986 TX0001896404
09/09/1986 August 27 1986 TX0001896403
09/09/1986 August 28 1986 TX0001896402
09/09/1986 August 29 1986 TX0001896407
09/09/1986 August 30 1986 TX0001896406
09/09/1986 August 31 1986 TX0001888108
09/17/1986 September 01 1986 TX0001908060
09/17/1986 September 02 1986 TX0001907750
09/17/1986 September 03 1986 TX0001907749
09/17/1986 September 04 1986 TX0001907748
09/17/1986 September 05 1986 TX0001907723
09/17/1986 September 06 1986 TX0001907724
09/17/1986 September 07 1986 TX0001907725
09/25/1986 September 08 1986 TX0001909186
09/25/1986 September 09 1986 TX0001909185
09/25/1986 September 10 1986 TX0001909189
09/25/1986 September 11 1986 TX0001909187
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 15 of 75

09/25/1986 September 12 1986 TX0001909188


09/25/1986 September 13 1986 TX0001909183
09/25/1986 September 14 1986 TX0001909184
10/01/1986 September 15 1986 TX0001918650
10/01/1986 September 16 1986 TX0001918649
10/01/1986 September 17 1986 TX0001918652
10/01/1986 September 18 1986 TX0001918653
10/01/1986 September 19 1986 TX0001918654
10/01/1986 September 20 1986 TX0001921603
10/01/1986 September 21 1986 TX0001918651
10/14/1986 September 22 1986 TX0001917156
10/14/1986 September 23 1986 TX0001917154
10/14/1986 September 24 1986 TX0001917155
10/14/1986 September 25 1986 TX0001914161
10/14/1986 September 26 1986 TX0001917162
10/14/1986 September 27 1986 TX0001917199
10/14/1986 September 28 1986 TX0001917129
10/14/1986 September 29 1986 TX0001927560
10/14/1986 September 30 1986 TX0001927561
10/14/1986 October 01 1986 TX0001917200
10/14/1986 October 02 1986 TX0001917165
10/14/1986 October 03 1986 TX0001917164
10/14/1986 October 04 1986 TX0001917163
10/14/1986 October 05 1986 TX0001917130
10/16/1986 October 06 1986 TX0001927596
10/16/1986 October 07 1986 TX0001927597
10/16/1986 October 08 1986 TX0001927595
10/16/1986 October 09 1986 TX0001927594
10/16/1986 October 10 1986 TX0001927598
10/16/1986 October 11 1986 TX0001927600
10/16/1986 October 12 1986 TX0001927601
10/28/1986 October 13 1986 TX0001943089
10/28/1986 October 14 1986 TX0001943088
10/28/1986 October 15 1986 TX0001943087
10/28/1986 October 16 1986 TX0001943096
10/28/1986 October 17 1986 TX0001943094
10/28/1986 October 18 1986 TX0001943093
10/28/1986 October 19 1986 TX0001943095
11/03/1986 October 20 1986 TX0001937788
11/03/1986 October 21 1986 TX0001937789
11/03/1986 October 22 1986 TX0001946645
11/03/1986 October 23 1986 TX0001946644
11/03/1986 October 24 1986 TX0001946637
11/03/1986 October 25 1986 TX0001946636
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 16 of 75

11/03/1986 October 26 1986 TX0001946650


11/10/1986 October 27 1986 TX0001944795
11/10/1986 October 28 1986 TX0001944794
11/10/1986 October 29 1986 TX0001944801
11/10/1986 October 30 1986 TX0001944802
11/10/1986 October 31 1986 TX0001944796
11/10/1986 November 01 1986 TX0001944798
11/10/1986 November 02 1986 TX0001944873
11/17/1986 November 03 1986 TX0001950597
11/17/1986 November 04 1986 TX0001950596
11/17/1986 November 05 1986 TX0001950600
11/17/1986 November 06 1986 TX0001950599
11/17/1986 November 07 1986 TX0001950598
11/17/1986 November 08 1986 TX0001950603
11/17/1986 November 09 1986 TX0001950602
11/24/1986 November 10 1986 TX0001944836
11/24/1986 November 11 1986 TX0001944837
11/24/1986 November 12 1986 TX0001944831
11/24/1986 November 13 1986 TX0001944833
11/24/1986 November 14 1986 TX0001944832
11/24/1986 November 15 1986 TX0001944835
11/24/1986 November 16 1986 TX0001944834
12/03/1986 November 17 1986 TX0001947222
12/03/1986 November 18 1986 TX0001951169
12/03/1986 November 19 1986 TX0001951170
12/03/1986 November 20 1986 TX0001951166
12/03/1986 November 21 1986 TX0001947218
12/03/1986 November 22 1986 TX0001947200
12/03/1986 November 23 1986 TX0001947221
12/08/1986 November 24 1986 TX0001960854
12/08/1986 November 25 1986 TX0001960855
12/08/1986 November 26 1986 TX0001960856
12/08/1986 November 27 1986 TX0001960857
12/08/1986 November 28 1986 TX0001960849
12/08/1986 November 29 1986 TX0001960853
12/08/1986 November 30 1986 TX0001960850
12/16/1986 December 01 1986 TX0001983741
12/16/1986 December 02 1986 TX0001983742
12/16/1986 December 03 1986 TX0001983743
12/16/1986 December 04 1986 TX0001971623
12/16/1986 December 05 1986 TX0001983739
12/16/1986 December 06 1986 TX0001983740
12/16/1986 December 07 1986 TX0001971621
12/23/1986 December 08 1986 TX0001977771
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 17 of 75

12/23/1986 December 09 1986 TX0001977772


12/23/1986 December 10 1986 TX0001977504
12/23/1986 December 11 1986 TX0001977505
12/23/1986 December 12 1986 TX0001977513
12/23/1986 December 13 1986 TX0001977770
12/23/1986 December 14 1986 TX0001977768
12/24/1986 December 15 1986 TX0001977557
12/24/1986 December 16 1986 TX0001977764
12/24/1986 December 17 1986 TX0001977763
12/24/1986 December 18 1986 TX0001977765
12/24/1986 December 19 1986 TX0001977776
12/24/1986 December 20 1986 TX0001977761
12/24/1986 December 21 1986 TX0001977558
01/05/1987 December 22 1986 TX0001987251
01/05/1987 December 23 1986 TX0001987264
01/05/1987 December 24 1986 TX0001987276
01/05/1987 December 25 1986 TX0001987275
01/05/1987 December 26 1986 TX0001987252
01/05/1987 December 27 1986 TX0001987282
01/05/1987 December 28 1986 TX0001987263
01/12/1987 December 29 1986 TX0001969484
01/12/1987 December 30 1986 TX0001969485
01/12/1987 December 31 1986 TX0001969483
02/25/1986 December 31 1985 TX0001825501
01/12/1987 January 01 1987 TX0001986609
01/12/1987 January 02 1987 TX0001969482
01/12/1987 January 03 1987 TX0001969486
01/12/1987 January 04 1987 TX0001969481
01/20/1987 January 05 1987 TX0001984181
01/20/1987 January 06 1987 TX0001984182
01/20/1987 January 07 1987 TX0001984202
01/20/1987 January 08 1987 TX0001984201
01/20/1987 January 09 1987 TX0001984200
01/20/1987 January 10 1987 TX0001984180
01/20/1987 January 11 1987 TX0001984190
01/27/1987 January 12 1987 TX0001984192
01/27/1987 January 13 1987 TX0001984193
01/27/1987 January 14 1987 TX0001984229
01/27/1987 January 15 1987 TX0001984198
01/27/1987 January 16 1987 TX0001984197
01/27/1987 January 17 1987 TX0001984191
01/27/1987 January 18 1987 TX0001984276
02/03/1987 January 19 1987 TX0001991464
02/03/1987 January 20 1987 TX0002007330
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 18 of 75

02/03/1987 January 21 1987 TX0002007375


02/03/1987 January 22 1987 TX0002007376
02/03/1987 January 23 1987 TX0002007377
02/03/1987 January 24 1987 TX0002007374
02/03/1987 January 25 1987 TX0001991460
02/11/1987 January 26 1987 TX0001990865
02/11/1987 January 27 1987 TX0001990861
02/11/1987 January 28 1987 TX0001990862
02/11/1987 January 29 1987 TX0001998006
02/11/1987 January 30 1987 TX0001990864
02/11/1987 January 31 1987 TX0001990863
02/11/1987 February 01 1987 TX0001998002
02/17/1987 February 02 1987 TX0001981194
02/17/1987 February 03 1987 TX0001981190
02/17/1987 February 04 1987 TX0001981191
02/17/1987 February 05 1987 TX0001981177
02/17/1987 February 06 1987 TX0001981188
02/17/1987 February 07 1987 TX0001981189
02/17/1987 February 08 1987 TX0001981192
02/24/1987 February 09 1987 TX0002003335
02/24/1987 February 10 1987 TX0002003356
02/24/1987 February 11 1987 TX0002003357
02/24/1987 February 12 1987 TX0002003362
02/24/1987 February 13 1987 TX0002003334
02/24/1987 February 14 1987 TX0002003358
02/24/1987 February 15 1987 TX0002003363
03/03/1987 February 16 1987 TX0002005014
03/03/1987 February 17 1987 TX0002014280
03/03/1987 February 18 1987 TX0002005015
03/03/1987 February 19 1987 TX0002005019
03/03/1987 February 20 1987 TX0002005017
03/03/1987 February 21 1987 TX0002005018
03/03/1987 February 22 1987 TX0002005081
03/10/1987 February 23 1987 TX0002016257
03/10/1987 February 24 1987 TX0002016258
03/10/1987 February 25 1987 TX0002027702
03/10/1987 February 26 1987 TX0002027556
03/10/1987 February 27 1987 TX0002027557
03/10/1987 February 28 1987 TX0002027558
03/10/1987 March 01 1987 TX0002027704
03/16/1987 March 02 1987 TX0002011945
03/16/1987 March 03 1987 TX0002027567
03/16/1987 March 04 1987 TX0002027568
03/16/1987 March 05 1987 TX0002016668
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 19 of 75

03/16/1987 March 06 1987 TX0002027554


03/16/1987 March 07 1987 TX0002027555
03/16/1987 March 08 1987 TX0002027703
03/25/1987 March 09 1987 TX0002024187
03/25/1987 March 10 1987 TX0002024198
03/25/1987 March 11 1987 TX0002024197
03/25/1987 March 12 1987 TX0002024182
03/25/1987 March 13 1987 TX0002024183
03/25/1987 March 14 1987 TX0002024184
03/25/1987 March 15 1987 TX0002024178
03/26/1987 March 16 1987 TX0002033676
03/26/1987 March 17 1987 TX0002033677
03/26/1987 March 18 1987 TX0002033678
03/26/1987 March 19 1987 TX0002033679
03/26/1987 March 20 1987 TX0002033680
03/26/1987 March 21 1987 TX0002033675
03/26/1987 March 22 1987 TX0002033681
04/21/1987 March 23 1987 TX0002053705
04/21/1987 March 24 1987 TX0002052186
04/21/1987 March 25 1987 TX0002052187
04/21/1987 March 26 1987 TX0002053711
04/21/1987 March 27 1987 TX0002055383
04/21/1987 March 28 1987 TX0002052185
04/21/1987 March 29 1987 TX0002055382
04/13/1987 March 30 1987 TX0002037595
04/13/1987 March 31 1987 TX0002037592
04/13/1987 April 01 1987 TX0002037594
04/13/1987 April 02 1987 TX0002037600
04/13/1987 April 03 1987 TX0002037597
04/13/1987 April 04 1987 TX0002037596
04/13/1987 April 05 1987 TX0002037593
04/23/1987 April 06 1987 TX0002051767
04/23/1987 April 07 1987 TX0002051768
04/23/1987 April 08 1987 TX0002051757
04/23/1987 April 09 1987 TX0002051756
04/23/1987 April 10 1987 TX0002051758
04/23/1987 April 11 1987 TX0002051766
04/23/1987 April 12 1987 TX0002051772
04/28/1987 April 13 1987 TX0002052182
04/28/1987 April 14 1987 TX0002052037
04/28/1987 April 15 1987 TX0002052040
04/28/1987 April 16 1987 TX0002052039
04/28/1987 April 17 1987 TX0002052038
04/28/1987 April 18 1987 TX0002052183
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 20 of 75

04/28/1987 April 19 1987 TX0002053651


05/05/1987 April 20 1987 TX0002053671
05/05/1987 April 21 1987 TX0002053669
05/05/1987 April 22 1987 TX0002053667
05/05/1987 April 23 1987 TX0002053668
05/05/1987 April 24 1987 TX0002053666
05/05/1987 April 25 1987 TX0002053665
05/05/1987 April 26 1987 TX0002053672
05/11/1987 April 27 1987 TX0002051992
05/11/1987 April 28 1987 TX0002051991
05/11/1987 April 29 1987 TX0002052013
05/11/1987 April 30 1987 TX0002052012
05/11/1987 May 01 1987 TX0002052011
05/11/1987 May 02 1987 TX0002052000
05/11/1987 May 03 1987 TX0002052004
05/19/1987 May 04 1987 TX0002065310
05/19/1987 May 05 1987 TX0002065304
05/19/1987 May 06 1987 TX0002065305
05/19/1987 May 07 1987 TX0002065311
05/19/1987 May 08 1987 TX0002065302
05/19/1987 May 09 1987 TX0002065303
05/19/1987 May 10 1987 TX0002065301
05/26/1987 May 11 1987 TX0002066476
05/26/1987 May 12 1987 TX0002066477
05/26/1987 May 13 1987 TX0002066478
05/26/1987 May 14 1987 TX0002066479
05/26/1987 May 15 1987 TX0002070585
05/26/1987 May 16 1987 TX0002070586
05/26/1987 May 17 1987 TX0002070587
06/02/1987 May 18 1987 TX0002074837
06/02/1987 May 19 1987 TX0002074838
06/02/1987 May 20 1987 TX0002074839
06/02/1987 May 21 1987 TX0002074840
06/02/1987 May 22 1987 TX0002074851
06/02/1987 May 23 1987 TX0002074852
06/02/1987 May 24 1987 TX0002074894
06/09/1987 May 25 1987 TX0002074830
06/09/1987 May 26 1987 TX0002074831
06/09/1987 May 27 1987 TX0002074828
06/09/1987 May 28 1987 TX0002074829
06/09/1987 May 29 1987 TX0002074826
06/09/1987 May 30 1987 TX0002074827
06/09/1987 May 31 1987 TX0002074897
06/22/1987 June 01 1987 TX0002085880
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 21 of 75

06/22/1987 June 02 1987 TX0002085882


06/22/1987 June 03 1987 TX0002085881
06/22/1987 June 04 1987 TX0002085883
06/22/1987 June 05 1987 TX0002085878
06/22/1987 June 06 1987 TX0002085877
06/22/1987 June 07 1987 TX0002085879
06/22/1987 June 08 1987 TX0002087845
06/22/1987 June 09 1987 TX0002087847
06/22/1987 June 10 1987 TX0002087848
06/22/1987 June 11 1987 TX0002087846
06/22/1987 June 12 1987 TX0002087852
06/22/1987 June 13 1987 TX0002087854
06/22/1987 June 14 1987 TX0002087857
06/29/1987 June 15 1987 TX0002089285
06/29/1987 June 16 1987 TX0002089284
06/29/1987 June 17 1987 TX0002092483
06/29/1987 June 17 1987 TX0002089288
06/29/1987 June 18 1987 TX0002089287
06/29/1987 June 19 1987 TX0002089290
06/29/1987 June 20 1987 TX0002089289
07/06/1987 June 22 1987 TX0002096852
07/06/1987 June 23 1987 TX0002096853
07/06/1987 June 24 1987 TX0002098535
07/06/1987 June 25 1987 TX0002098536
07/06/1987 June 26 1987 TX0002098537
07/06/1987 June 27 1987 TX0002098538
07/06/1987 June 28 1987 TX0002098539
07/16/1987 June 29 1987 TX0002106522
07/16/1987 June 30 1987 TX0002106523
07/16/1987 July 01 1987 TX0002106524
07/16/1987 July 02 1987 TX0002106525
07/16/1987 July 03 1987 TX0002106526
07/16/1987 July 04 1987 TX0002106527
07/16/1987 July 05 1987 TX0002106521
07/27/1987 July 06 1987 TX0002113738
07/27/1987 July 07 1987 TX0002123374
07/27/1987 July 08 1987 TX0002113731
07/27/1987 July 09 1987 TX0002113733
07/27/1987 July 10 1987 TX0002113730
07/27/1987 July 11 1987 TX0002113735
07/27/1987 July 12 1987 TX0002113729
07/27/1987 July 13 1987 TX0002113739
07/27/1987 July 14 1987 TX0002113734
07/27/1987 July 15 1987 TX0002113732
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 22 of 75

07/27/1987 July 16 1987 TX0002113741


07/27/1987 July 17 1987 TX0002113736
07/27/1987 July 18 1987 TX0002113740
07/27/1987 July 19 1987 TX0002113737
08/04/1987 July 20 1987 TX0002117493
08/04/1987 July 21 1987 TX0002117491
08/04/1987 July 22 1987 TX0002117492
08/04/1987 July 23 1987 TX0002117489
08/04/1987 July 24 1987 TX0002117490
08/04/1987 July 25 1987 TX0002117487
08/04/1987 July 26 1987 TX0002117488
08/10/1987 July 27 1987 TX0002123988
08/10/1987 July 28 1987 TX0002122376
08/10/1987 July 29 1987 TX0002122375
08/10/1987 July 30 1987 TX0002122374
08/10/1987 July 31 1987 TX0002122373
08/10/1987 August 01 1987 TX0002122370
08/10/1987 August 02 1987 TX0002122377
08/18/1987 August 03 1987 TX0002127785
08/18/1987 August 04 1987 TX0002126770
08/18/1987 August 05 1987 TX0002126771
08/18/1987 August 06 1987 TX0002126772
08/18/1987 August 07 1987 TX0002126773
08/18/1987 August 08 1987 TX0002126774
08/18/1987 August 09 1987 TX0002127784
08/24/1987 August 10 1987 TX0002130985
08/24/1987 August 11 1987 TX0002130984
08/24/1987 August 12 1987 TX0002130983
08/24/1987 August 13 1987 TX0002130982
08/24/1987 August 14 1987 TX0002130981
08/24/1987 August 15 1987 TX0002130980
08/24/1987 August 16 1987 TX0002136903
08/28/1987 August 17 1987 TX0002135440
08/28/1987 August 18 1987 TX0002135441
08/28/1987 August 19 1987 TX0002135445
08/28/1987 August 20 1987 TX0002135444
08/28/1987 August 21 1987 TX0002135443
08/28/1987 August 22 1987 TX0002135442
08/28/1987 August 23 1987 TX0002135439
09/08/1987 August 24 1987 TX0002143349
09/08/1987 August 25 1987 TX0002146571
09/08/1987 August 26 1987 TX0002143348
09/08/1987 August 27 1987 TX0002146572
09/08/1987 August 28 1987 TX0002143350
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 23 of 75

09/08/1987 August 29 1987 TX0002146570


09/08/1987 August 30 1987 TX0002143781
09/14/1987 August 31 1987 TX0002143765
09/14/1987 September 01 1987 TX0002143779
09/14/1987 September 03 1987 TX0002143766
09/14/1987 September 04 1987 TX0002143768
09/14/1987 September 05 1987 TX0002143767
09/14/1987 September 06 1987 TX0002143769
09/21/1987 September 07 1987 TX0002146710
09/21/1987 September 08 1987 TX0002146711
09/21/1987 September 09 1987 TX0002146712
09/21/1987 September 10 1987 TX0002144925
09/21/1987 September 11 1987 TX0002144926
09/21/1987 September 12 1987 TX0002144927
09/21/1987 September 13 1987 TX0002144931
09/23/1987 September 14 1987 TX0002167848
09/23/1987 September 15 1987 TX0002167849
09/23/1987 September 16 1987 TX0002167845
09/23/1987 September 17 1987 TX0002160084
09/23/1987 September 18 1987 TX0002167846
09/23/1987 September 19 1987 TX0002167847
09/23/1987 September 20 1987 TX0002166006
10/05/1987 September 21 1987 TX0002185804
10/05/1987 September 22 1987 TX0002185805
10/05/1987 September 23 1987 TX0002154089
10/05/1987 September 24 1987 TX0002154090
10/05/1987 September 25 1987 TX0002154091
10/05/1987 September 26 1987 TX0002154098
10/05/1987 September 27 1987 TX0002185806
10/13/1987 September 28 1987 TX0002164857
10/13/1987 September 29 1987 TX0002164858
10/13/1987 September 30 1987 TX0002164859
10/13/1987 October 01 1987 TX0002164860
10/13/1987 October 02 1987 TX0002164861
10/13/1987 October 03 1987 TX0002164862
10/13/1987 October 04 1987 TX0002164856
10/26/1987 October 05 1987 TX0002164313
10/26/1987 October 06 1987 TX0002164321
10/26/1987 October 07 1987 TX0002164322
10/26/1987 October 08 1987 TX0002164312
10/28/1987 October 09 1987 TX0002171319
10/26/1987 October 10 1987 TX0002164311
10/26/1987 October 11 1987 TX0002170798
10/27/1987 October 12 1987 TX0002169895
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 24 of 75

10/27/1987 October 13 1987 TX0002169896


10/27/1987 October 14 1987 TX0002169897
10/27/1987 October 15 1987 TX0002169898
10/27/1987 October 16 1987 TX0002169893
10/27/1987 October 17 1987 TX0002169894
10/27/1987 October 18 1987 TX0002169892
11/02/1987 October 19 1987 TX0002196480
11/02/1987 October 20 1987 TX0002178275
11/02/1987 October 21 1987 TX0002185678
11/02/1987 October 22 1987 TX0002185633
11/02/1987 October 23 1987 TX0002178277
11/02/1987 October 24 1987 TX0002178278
11/02/1987 October 25 1987 TX0002178282
11/12/1987 October 26 1987 TX0002202981
11/12/1987 October 27 1987 TX0002202985
11/12/1987 October 28 1987 TX0002202986
11/12/1987 October 29 1987 TX0002188930
11/12/1987 October 30 1987 TX0002188929
11/12/1987 October 31 1987 TX0002188928
11/12/1987 November 01 1987 TX0002202987
11/19/1987 November 02 1987 TX0002196504
11/19/1987 November 03 1987 TX0002196505
11/19/1987 November 04 1987 TX0002196506
11/19/1987 November 05 1987 TX0002196502
11/19/1987 November 06 1987 TX0002196503
11/19/1987 November 07 1987 TX0002196507
11/19/1987 November 08 1987 TX0002196501
11/23/1987 November 09 1987 TX0002194870
11/23/1987 November 10 1987 TX0002195225
11/23/1987 November 11 1987 TX0002195215
11/23/1987 November 12 1987 TX0002195214
11/23/1987 November 13 1987 TX0002195209
11/23/1987 November 14 1987 TX0002195213
11/23/1987 November 15 1987 TX0002195228
11/27/1987 November 16 1987 TX0002199704
11/27/1987 November 17 1987 TX0002199705
11/27/1987 November 18 1987 TX0002199703
11/27/1987 November 19 1987 TX0002201936
11/27/1987 November 20 1987 TX0002199799
11/27/1987 November 21 1987 TX0002199800
11/27/1987 November 22 1987 TX0002199798
12/10/1987 November 23 1987 TX0002201202
12/10/1987 November 24 1987 TX0002201203
12/10/1987 November 25 1987 TX0002201204
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 25 of 75

12/10/1987 November 26 1987 TX0002201207


12/10/1987 November 27 1987 TX0002201206
12/10/1987 November 28 1987 TX0002201208
12/10/1987 November 29 1987 TX0002201209
12/14/1987 November 30 1987 TX0002200760
12/14/1987 December 01 1987 TX0002199455
12/14/1987 December 02 1987 TX0002200756
12/14/1987 December 03 1987 TX0002200757
12/14/1987 December 04 1987 TX0002200758
12/14/1987 December 05 1987 TX0002200759
12/14/1987 December 06 1987 TX0002199457
01/04/1988 December 07 1987 TX0002231645
01/04/1988 December 08 1987 TX0002231644
01/04/1988 December 09 1987 TX0002231640
01/04/1988 December 10 1987 TX0002223201
01/04/1988 December 11 1987 TX0002231641
01/04/1988 December 12 1987 TX0002223202
12/29/1987 December 14 1987 TX0002211407
12/29/1987 December 15 1987 TX0002211394
12/29/1987 December 16 1987 TX0002211393
12/29/1987 December 17 1987 TX0002211836
12/29/1987 December 18 1987 TX0002211835
12/29/1987 December 19 1987 TX0002211834
12/29/1987 December 20 1987 TX0002211833
01/04/1988 December 21 1987 TX0002231643
01/04/1988 December 22 1987 TX0002223200
01/04/1988 December 23 1987 TX0002231642
01/04/1988 December 24 1987 TX0002223373
01/04/1988 December 25 1987 TX0002223377
01/04/1988 December 26 1987 TX0002223376
01/04/1988 December 27 1987 TX0002231646
01/11/1988 December 28 1987 TX0002231361
01/11/1988 December 29 1987 TX0002231442
01/11/1988 December 30 1987 TX0002231356
01/11/1988 December 31 1987 TX0002231443
01/11/1988 January 01 1988 TX0002231545
01/11/1988 January 02 1988 TX0002231357
01/11/1988 January 03 1988 TX0002229178
01/19/1988 January 04 1988 TX0002236218
01/19/1988 January 05 1988 TX0002236219
01/19/1988 January 06 1988 TX0002236202
01/19/1988 January 07 1988 TX0002236203
01/19/1988 January 08 1988 TX0002236220
01/19/1988 January 09 1988 TX0002236298
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 26 of 75

01/19/1988 January 10 1988 TX0002236201


02/05/1988 January 11 1988 TX0002241361
02/05/1988 January 12 1988 TX0002241362
02/05/1988 January 13 1988 TX0002262944
02/05/1988 January 14 1988 TX0002241360
02/05/1988 January 15 1988 TX0002241358
02/05/1988 January 16 1988 TX0002241359
02/05/1988 January 17 1988 TX0002241363
02/02/1988 January 18 1988 TX0002237915
02/02/1988 January 19 1988 TX0002237917
02/02/1988 January 20 1988 TX0002237916
02/02/1988 January 21 1988 TX0002237901
02/02/1988 January 22 1988 TX0002237913
02/02/1988 January 23 1988 TX0002237914
02/02/1988 January 24 1988 TX0002237946
02/09/1988 January 25 1988 TX0002241366
02/09/1988 January 26 1988 TX0002241351
02/09/1988 January 27 1988 TX0002241368
02/09/1988 January 28 1988 TX0002241398
02/09/1988 January 29 1988 TX0002241397
02/09/1988 January 30 1988 TX0002241367
02/09/1988 January 31 1988 TX0002241399
02/17/1988 February 01 1988 TX0002249794
02/17/1988 February 02 1988 TX0002249776
02/17/1988 February 03 1988 TX0002249771
02/17/1988 February 04 1988 TX0002249775
02/17/1988 February 05 1988 TX0002249798
02/17/1988 February 06 1988 TX0002249772
02/17/1988 February 07 1988 TX0002249777
02/22/1988 February 08 1988 TX0002237445
02/22/1988 February 09 1988 TX0002237446
02/22/1988 February 10 1988 TX0002237447
02/22/1988 February 11 1988 TX0002237450
02/22/1988 February 12 1988 TX0002237449
02/22/1988 February 13 1988 TX0002237457
02/22/1988 February 14 1988 TX0002237948
02/29/1988 February 15 1988 TX0002253750
02/29/1988 February 16 1988 TX0002253749
02/29/1988 February 17 1988 TX0002253748
02/29/1988 February 18 1988 TX0002253747
02/29/1988 February 19 1988 TX0002253746
02/29/1988 February 20 1988 TX0002253745
02/29/1988 February 21 1988 TX0002253744
03/08/1988 February 22 1988 TX0002264823
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 27 of 75

03/08/1988 February 23 1988 TX0002264822


03/08/1988 February 24 1988 TX0002264821
03/08/1988 February 25 1988 TX0002264825
03/08/1988 February 26 1988 TX0002264824
03/08/1988 February 27 1988 TX0002270436
03/08/1988 February 28 1988 TX0002264828
03/15/1988 February 29 1988 TX0002265471
03/15/1988 March 01 1988 TX0002265463
03/15/1988 March 02 1988 TX0002265462
03/15/1988 March 03 1988 TX0002265465
03/15/1988 March 04 1988 TX0002265464
03/15/1988 March 05 1988 TX0002265429
03/15/1988 March 06 1988 TX0002265466
03/21/1988 March 07 1988 TX0002272145
03/21/1988 March 08 1988 TX0002272153
03/21/1988 March 09 1988 TX0002272160
03/21/1988 March 10 1988 TX0002272196
03/21/1988 March 11 1988 TX0002272181
03/21/1988 March 12 1988 TX0002272175
03/21/1988 March 13 1988 TX0002272158
03/29/1988 March 14 1988 TX0002271968
03/29/1988 March 15 1988 TX0002271969
03/29/1988 March 16 1988 TX0002271970
03/29/1988 March 17 1988 TX0002271974
03/29/1988 March 18 1988 TX0002271973
03/29/1988 March 19 1988 TX0002271972
03/29/1988 March 20 1988 TX0002272148
04/06/1988 March 21 1988 TX0002295598
04/06/1988 March 22 1988 TX0002295597
04/06/1988 March 23 1988 TX0002285250
04/06/1988 March 24 1988 TX0002285249
04/06/1988 March 25 1988 TX0002295591
04/06/1988 March 26 1988 TX0002295795
04/06/1988 March 27 1988 TX0002295796
04/14/1988 March 28 1988 TX0002298145
04/14/1988 March 29 1988 TX0002298149
04/14/1988 March 30 1988 TX0002298150
04/14/1988 March 31 1988 TX0002298146
04/14/1988 April 01 1988 TX0002298147
04/14/1988 April 02 1988 TX0002298148
04/14/1988 April 03 1988 TX0002285350
04/14/1988 April 04 1988 TX0002285352
04/14/1988 April 05 1988 TX0002285351
04/14/1988 April 06 1988 TX0002298136
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 28 of 75

04/14/1988 April 07 1988 TX0002298144


04/14/1988 April 08 1988 TX0002298143
04/14/1988 April 09 1988 TX0002298138
04/14/1988 April 10 1988 TX0002285348
04/25/1988 April 11 1988 TX0002296520
04/25/1988 April 12 1988 TX0002296519
04/25/1988 April 13 1988 TX0002296518
04/25/1988 April 14 1988 TX0002297136
04/25/1988 April 15 1988 TX0002297133
04/25/1988 April 16 1988 TX0002297134
04/25/1988 April 17 1988 TX0002297135
05/09/1988 April 18 1988 TX0002306074
05/09/1988 April 19 1988 TX0002306087
05/09/1988 April 20 1988 TX0002306076
05/09/1988 April 21 1988 TX0002306075
05/09/1988 April 22 1988 TX0002306077
05/09/1988 April 23 1988 TX0002306078
05/09/1988 April 24 1988 TX0002306088
05/09/1988 April 25 1988 TX0002306090
05/09/1988 April 26 1988 TX0002306089
05/09/1988 April 27 1988 TX0002304154
05/09/1988 April 28 1988 TX0002304150
05/09/1988 April 29 1988 TX0002304151
05/09/1988 April 30 1988 TX0002306072
05/09/1988 May 01 1988 TX0002304155
05/17/1988 May 02 1988 TX0002303975
05/17/1988 May 03 1988 TX0002303976
05/17/1988 May 04 1988 TX0002303977
05/17/1988 May 05 1988 TX0002303974
05/17/1988 May 06 1988 TX0002303968
05/17/1988 May 07 1988 TX0002303973
05/17/1988 May 08 1988 TX0002303972
05/24/1988 May 09 1988 TX0002310674
05/24/1988 May 10 1988 TX0002310675
05/24/1988 May 11 1988 TX0002310676
05/24/1988 May 12 1988 TX0002308586
05/24/1988 May 13 1988 TX0002308587
05/24/1988 May 14 1988 TX0002310673
05/24/1988 May 15 1988 TX0002348003
05/31/1988 May 16 1988 TX0002342086
05/31/1988 May 17 1988 TX0002342087
05/31/1988 May 18 1988 TX0002350970
05/31/1988 May 19 1988 TX0002350971
05/31/1988 May 20 1988 TX0002342088
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 29 of 75

05/31/1988 May 21 1988 TX0002342089


05/31/1988 May 22 1988 TX0002350975
06/07/1988 May 23 1988 TX0002332056
06/07/1988 May 24 1988 TX0002332055
06/07/1988 May 25 1988 TX0002332057
06/07/1988 May 26 1988 TX0002332054
06/07/1988 May 27 1988 TX0002332053
06/07/1988 May 28 1988 TX0002332058
06/07/1988 May 29 1988 TX0002332052
06/17/1988 May 30 1988 TX0002342030
06/17/1988 May 31 1988 TX0002337204
06/17/1988 June 01 1988 TX0002337205
06/17/1988 June 02 1988 TX0002337206
06/17/1988 June 03 1988 TX0002342032
06/17/1988 June 04 1988 TX0002342031
06/17/1988 June 05 1988 TX0002337207
06/22/1988 June 06 1988 TX0002348009
06/22/1988 June 07 1988 TX0002348010
06/22/1988 June 08 1988 TX0002348011
06/22/1988 June 09 1988 TX0002348012
06/22/1988 June 10 1988 TX0002348007
06/22/1988 June 11 1988 TX0002348008
06/22/1988 June 12 1988 TX0002348006
06/29/1988 June 13 1988 TX0002345695
06/29/1988 June 14 1988 TX0002345691
06/29/1988 June 15 1988 TX0002332068
06/29/1988 June 16 1988 TX0002332069
06/29/1988 June 17 1988 TX0002332066
07/07/1988 June 18 1988 TX0002345751
07/07/1988 June 19 1988 TX0002345749
07/05/1988 June 20 1988 TX0002345754
07/05/1988 June 21 1988 TX0002345755
07/05/1988 June 22 1988 TX0002345756
07/05/1988 June 23 1988 TX0002345757
07/05/1988 June 24 1988 TX0002345758
07/05/1988 June 25 1988 TX0002345759
07/05/1988 June 26 1988 TX0002345762
07/12/1988 June 27 1988 TX0002342104
07/12/1988 June 28 1988 TX0002342103
07/12/1988 June 29 1988 TX0002342102
07/12/1988 June 30 1988 TX0002342109
07/12/1988 July 01 1988 TX0002342107
07/12/1988 July 02 1988 TX0002342106
07/12/1988 July 03 1988 TX0002342105
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 30 of 75

07/18/1988 July 04 1988 TX0002349196


07/18/1988 July 05 1988 TX0002349197
07/18/1988 July 06 1988 TX0002350955
07/18/1988 July 07 1988 TX0002350956
07/18/1988 July 08 1988 TX0002350957
07/18/1988 July 09 1988 TX0002350958
07/18/1988 July 10 1988 TX0002350959
07/26/1988 July 11 1988 TX0002361839
07/26/1988 July 12 1988 TX0002361844
07/26/1988 July 13 1988 TX0002361603
07/26/1988 July 14 1988 TX0002361590
07/26/1988 July 15 1988 TX0002361602
07/26/1988 July 16 1988 TX0002361589
07/26/1988 July 17 1988 TX0002361841
08/05/1988 July 18 1988 TX0002369227
08/05/1988 July 19 1988 TX0002369223
08/05/1988 July 20 1988 TX0002369221
08/05/1988 July 21 1988 TX0002369228
08/05/1988 July 22 1988 TX0002369224
08/05/1988 July 23 1988 TX0002372578
08/05/1988 July 24 1988 TX0002368916
08/05/1988 July 25 1988 TX0002362451
08/05/1988 July 26 1988 TX0002362450
08/05/1988 July 27 1988 TX0002362449
08/05/1988 July 28 1988 TX0002362448
08/05/1988 July 29 1988 TX0002362447
08/05/1988 July 30 1988 TX0002362446
08/05/1988 July 31 1988 TX0002362445
08/15/1988 August 01 1988 TX0002372531
08/15/1988 August 02 1988 TX0002372530
08/15/1988 August 03 1988 TX0002372528
08/15/1988 August 04 1988 TX0002372529
08/15/1988 August 05 1988 TX0002372527
08/15/1988 August 06 1988 TX0002372526
08/15/1988 August 07 1988 TX0002372533
08/23/1988 August 08 1988 TX0002376556
08/23/1988 August 09 1988 TX0002376560
08/23/1988 August 10 1988 TX0002376561
08/23/1988 August 11 1988 TX0002376557
08/23/1988 August 12 1988 TX0002376562
08/23/1988 August 13 1988 TX0002376558
08/23/1988 August 14 1988 TX0002376559
08/29/1988 August 15 1988 TX0002383829
08/29/1988 August 16 1988 TX0002383830
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 31 of 75

08/29/1988 August 17 1988 TX0002383831


08/29/1988 August 18 1988 TX0002391657
08/29/1988 August 19 1988 TX0002391656
08/29/1988 August 20 1988 TX0002391600
08/29/1988 August 21 1988 TX0002391635
09/06/1988 August 22 1988 TX0002388063
09/06/1988 August 23 1988 TX0002388062
09/06/1988 August 24 1988 TX0002387985
09/06/1988 August 25 1988 TX0002387975
09/06/1988 August 26 1988 TX0002387937
09/06/1988 August 27 1988 TX0002387970
09/06/1988 August 28 1988 TX0002383035
09/19/1988 August 29 1988 TX0002415533
09/19/1988 August 31 1988 TX0002395550
09/19/1988 September 01 1988 TX0002401456
09/19/1988 September 02 1988 TX0002399295
09/19/1988 September 03 1988 TX0002424841
09/19/1988 September 04 1988 TX0002399296
09/16/1988 September 05 1988 TX0002395549
09/16/1988 September 06 1988 TX0002395544
09/16/1988 September 07 1988 TX0002395545
09/16/1988 September 08 1988 TX0002395546
09/16/1988 September 09 1988 TX0002395547
09/16/1988 September 10 1988 TX0002395548
09/16/1988 September 11 1988 TX0002405048
09/27/1988 September 12 1988 TX0002417645
09/27/1988 September 13 1988 TX0002417644
09/27/1988 September 14 1988 TX0002417648
09/27/1988 September 15 1988 TX0002417643
09/27/1988 September 16 1988 TX0002417646
09/27/1988 September 17 1988 TX0002417642
09/27/1988 September 18 1988 TX0002417647
10/04/1988 September 19 1988 TX0002401445
10/04/1988 September 20 1988 TX0002401444
10/04/1988 September 21 1988 TX0002418483
10/04/1988 September 22 1988 TX0002401442
10/04/1988 September 23 1988 TX0002401443
10/04/1988 September 24 1988 TX0002401446
10/04/1988 September 25 1988 TX0002401441
10/07/1988 September 26 1988 TX0002441391
10/07/1988 September 27 1988 TX0002441364
10/07/1988 September 28 1988 TX0002441365
10/07/1988 September 29 1988 TX0002441390
10/07/1988 September 30 1988 TX0002441366
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 32 of 75

10/07/1988 October 01 1988 TX0002441367


10/07/1988 October 02 1988 TX0002441389
10/17/1988 October 03 1988 TX0002412012
10/17/1988 October 04 1988 TX0002412008
10/17/1988 October 05 1988 TX0002412007
10/17/1988 October 06 1988 TX0002412021
10/17/1988 October 07 1988 TX0002412020
10/17/1988 October 08 1988 TX0002412009
10/17/1988 October 09 1988 TX0002412010
10/31/1988 October 10 1988 TX0002425297
10/31/1988 October 11 1988 TX0002425300
10/31/1988 October 12 1988 TX0002425085
10/31/1988 October 13 1988 TX0002425086
10/31/1988 October 14 1988 TX0002426483
10/31/1988 October 15 1988 TX0002426484
10/31/1988 October 17 1988 TX0002425087
10/31/1988 October 18 1988 TX0002425088
10/31/1988 October 19 1988 TX0002425303
10/31/1988 October 20 1988 TX0002425304
10/31/1988 October 21 1988 TX0002425301
10/31/1988 October 22 1988 TX0002425302
10/31/1988 October 23 1988 TX0002426485
11/02/1988 October 24 1988 TX0002433916
11/02/1988 October 25 1988 TX0002433915
11/02/1988 October 26 1988 TX0002433905
11/02/1988 October 27 1988 TX0002433909
11/02/1988 October 28 1988 TX0002433907
11/02/1988 October 29 1988 TX0002433906
11/02/1988 October 30 1988 TX0002433917
11/14/1988 November 06 1988 TX0002444387
11/25/1988 November 07 1988 TX0002444327
11/25/1988 November 08 1988 TX0002441566
11/25/1988 November 09 1988 TX0002444329
11/25/1988 November 10 1988 TX0002441569
11/25/1988 November 11 1988 TX0002441568
11/25/1988 November 12 1988 TX0002444328
11/25/1988 November 13 1988 TX0002441600
11/28/1988 November 14 1988 TX0002441591
11/28/1988 November 15 1988 TX0002441590
11/28/1988 November 16 1988 TX0002441593
11/28/1988 November 17 1988 TX0002441592
11/28/1988 November 18 1988 TX0002444337
11/28/1988 November 19 1988 TX0002444335
11/28/1988 November 20 1988 TX0002444334
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 33 of 75

12/02/1988 November 22 1988 TX0002451352


12/02/1988 November 23 1988 TX0002450198
12/02/1988 November 24 1988 TX0002450020
12/02/1988 November 25 1988 TX0002450019
12/02/1988 November 26 1988 TX0002446929
12/02/1988 November 27 1988 TX0002446930
12/08/1988 November 28 1988 TX0002450240
12/08/1988 November 29 1988 TX0002450241
12/08/1988 November 30 1988 TX0002476343
12/08/1988 December 01 1988 TX0002451443
12/08/1988 December 02 1988 TX0002451442
12/08/1988 December 03 1988 TX0002451393
12/08/1988 December 04 1988 TX0002451461
12/19/1988 December 05 1988 TX0002454466
12/19/1988 December 06 1988 TX0002454465
12/19/1988 December 07 1988 TX0002454464
12/19/1988 December 08 1988 TX0002454468
12/19/1988 December 09 1988 TX0002454467
12/19/1988 December 10 1988 TX0002454463
12/19/1988 December 11 1988 TX0002454462
12/22/1988 December 12 1988 TX0002462582
12/22/1988 December 13 1988 TX0002462581
12/22/1988 December 14 1988 TX0002465774
12/22/1988 December 15 1988 TX0002465773
12/22/1988 December 16 1988 TX0002462562
12/22/1988 December 17 1988 TX0002462563
12/22/1988 December 18 1988 TX0002462583
01/03/1989 December 19 1988 TX0002465633
01/03/1989 December 20 1988 TX0002465611
01/03/1989 December 21 1988 TX0002465610
01/03/1989 December 22 1988 TX0002465634
01/03/1989 December 23 1988 TX0002465612
01/03/1989 December 24 1988 TX0002465631
01/03/1989 December 25 1988 TX0002465632
01/05/1989 December 26 1988 TX0002465683
01/05/1989 December 27 1988 TX0002465684
01/05/1989 December 28 1988 TX0002465685
01/05/1989 December 29 1988 TX0002465682
01/05/1989 December 30 1988 TX0002465681
01/05/1989 December 31 1988 TX0002466402
01/05/1989 January 01 1989 TX0002465696
01/18/1989 January 02 1989 TX0002493115
01/18/1989 January 03 1989 TX0002493116
01/18/1989 January 04 1989 TX0002493114
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 34 of 75

01/18/1989 January 05 1989 TX0002493112


01/18/1989 January 06 1989 TX0002493113
01/18/1989 January 07 1989 TX0002493111
01/18/1989 January 08 1989 TX0002493206
01/19/1989 January 09 1989 TX0002475029
01/19/1989 January 10 1989 TX0002475030
01/19/1989 January 11 1989 TX0002475031
01/19/1989 January 12 1989 TX0002475026
01/19/1989 January 13 1989 TX0002475027
01/19/1989 January 14 1989 TX0002475028
01/19/1989 January 15 1989 TX0002475025
02/15/1989 January 16 1989 TX0002493726
02/15/1989 January 17 1989 TX0002493720
02/15/1989 January 18 1989 TX0002493719
02/15/1989 January 19 1989 TX0002493725
02/15/1989 January 20 1989 TX0002493724
02/15/1989 January 21 1989 TX0002493706
02/15/1989 January 22 1989 TX0002493707
02/07/1989 January 23 1989 TX0002485560
02/07/1989 January 24 1989 TX0002485561
02/07/1989 January 25 1989 TX0002485559
02/07/1989 January 26 1989 TX0002485588
02/07/1989 January 27 1989 TX0002485557
02/07/1989 January 28 1989 TX0002485558
02/13/1989 January 30 1989 TX0002491695
02/13/1989 January 31 1989 TX0002491694
02/13/1989 February 01 1989 TX0002491693
02/13/1989 February 02 1989 TX0002491563
02/13/1989 February 03 1989 TX0002491559
02/13/1989 February 04 1989 TX0002491562
02/13/1989 February 05 1989 TX0002491696
02/16/1989 February 06 1989 TX0002493753
02/16/1989 February 07 1989 TX0002493752
02/16/1989 February 08 1989 TX0002493751
02/16/1989 February 09 1989 TX0002498813
02/16/1989 February 10 1989 TX0002498814
02/16/1989 February 11 1989 TX0002493756
02/16/1989 February 12 1989 TX0002498815
02/28/1989 February 13 1989 TX0002523229
02/28/1989 February 14 1989 TX0002552675
02/28/1989 February 15 1989 TX0002552674
02/28/1989 February 16 1989 TX0002552673
02/28/1989 February 17 1989 TX0002552672
02/28/1989 February 18 1989 TX0002552671
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 35 of 75

02/28/1989 February 19 1989 TX0002552676


03/09/1989 February 20 1989 TX0002538501
03/09/1989 February 21 1989 TX0002538504
03/09/1989 February 22 1989 TX0002538500
03/09/1989 February 23 1989 TX0002537884
03/09/1989 February 24 1989 TX0002538503
03/09/1989 February 25 1989 TX0002538502
03/09/1989 February 26 1989 TX0002537885
03/09/1989 February 27 1989 TX0002508828
03/09/1989 February 28 1989 TX0002508827
03/09/1989 March 01 1989 TX0002508826
03/09/1989 March 02 1989 TX0002508829
03/09/1989 March 03 1989 TX0002508825
03/09/1989 March 04 1989 TX0002508855
03/09/1989 March 05 1989 TX0002508853
03/17/1989 March 06 1989 TX0002523784
03/17/1989 March 07 1989 TX0002523783
03/17/1989 March 08 1989 TX0002523782
03/17/1989 March 09 1989 TX0002523781
03/17/1989 March 10 1989 TX0002523785
03/17/1989 March 11 1989 TX0002523786
03/17/1989 March 12 1989 TX0002523780
03/24/1989 March 13 1989 TX0002521637
03/24/1989 March 14 1989 TX0002521638
03/24/1989 March 15 1989 TX0002521635
03/24/1989 March 16 1989 TX0002519014
03/24/1989 March 17 1989 TX0002519013
03/24/1989 March 18 1989 TX0002519012
03/24/1989 March 19 1989 TX0002521634
03/29/1989 March 20 1989 TX0002519038
03/29/1989 March 21 1989 TX0002519037
03/29/1989 March 22 1989 TX0002519030
03/29/1989 March 23 1989 TX0002519031
03/29/1989 March 24 1989 TX0002519034
03/29/1989 March 25 1989 TX0002519042
03/29/1989 March 26 1989 TX0002519027
04/07/1989 March 27 1989 TX0002532796
04/07/1989 March 28 1989 TX0002536298
04/07/1989 March 29 1989 TX0002536299
04/07/1989 March 30 1989 TX0002532793
04/07/1989 March 31 1989 TX0002532795
04/07/1989 April 01 1989 TX0002532794
04/07/1989 April 02 1989 TX0002535716
04/13/1989 April 03 1989 TX0002536259
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 36 of 75

04/13/1989 April 04 1989 TX0002536258


04/13/1989 April 05 1989 TX0002536257
04/13/1989 April 06 1989 TX0002536253
04/13/1989 April 07 1989 TX0002537750
04/13/1989 April 08 1989 TX0002536256
04/13/1989 April 09 1989 TX0002536317
04/19/1989 April 10 1989 TX0002537698
04/19/1989 April 11 1989 TX0002537868
04/19/1989 April 12 1989 TX0002537869
04/19/1989 April 13 1989 TX0002537874
04/19/1989 April 14 1989 TX0002537873
04/19/1989 April 15 1989 TX0002537871
04/19/1989 April 16 1989 TX0002537870
04/26/1989 April 17 1989 TX0002553785
04/26/1989 April 18 1989 TX0002553784
04/26/1989 April 19 1989 TX0002553783
04/26/1989 April 20 1989 TX0002553782
04/26/1989 April 21 1989 TX0002553788
04/26/1989 April 22 1989 TX0002553787
04/26/1989 April 23 1989 TX0002538554
05/04/1989 April 24 1989 TX0002543116
05/04/1989 April 25 1989 TX0002543117
05/04/1989 April 26 1989 TX0002543118
05/04/1989 April 27 1989 TX0002543119
05/04/1989 April 28 1989 TX0002543120
05/04/1989 April 29 1989 TX0002571872
05/04/1989 April 30 1989 TX0002571873
05/15/1989 May 01 1989 TX0002557438
05/15/1989 May 02 1989 TX0002557440
05/15/1989 May 03 1989 TX0002557439
05/15/1989 May 04 1989 TX0002557441
05/15/1989 May 05 1989 TX0002557425
05/15/1989 May 06 1989 TX0002557426
05/15/1989 May 07 1989 TX0002557437
05/19/1989 May 08 1989 TX0002557435
05/19/1989 May 09 1989 TX0002557430
05/19/1989 May 10 1989 TX0002557431
05/19/1989 May 11 1989 TX0002557427
05/19/1989 May 12 1989 TX0002557423
05/19/1989 May 13 1989 TX0002557424
05/19/1989 May 14 1989 TX0002567020
05/26/1989 May 15 1989 TX0002565696
05/26/1989 May 16 1989 TX0002565697
05/26/1989 May 17 1989 TX0002565698
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 37 of 75

05/26/1989 May 18 1989 TX0002565699


05/26/1989 May 19 1989 TX0002565700
05/26/1989 May 20 1989 TX0002565701
05/26/1989 May 21 1989 TX0002565695
06/05/1989 May 22 1989 TX0002575323
06/05/1989 May 23 1989 TX0002575322
06/05/1989 May 24 1989 TX0002575335
06/05/1989 May 25 1989 TX0002575375
06/05/1989 May 26 1989 TX0002575374
06/05/1989 May 27 1989 TX0002571857
06/05/1989 May 28 1989 TX0002575423
06/09/1989 May 29 1989 TX0002575329
06/09/1989 May 30 1989 TX0002575330
06/09/1989 May 31 1989 TX0002575325
06/09/1989 June 01 1989 TX0002575380
06/09/1989 June 02 1989 TX0002575331
06/09/1989 June 03 1989 TX0002575360
06/09/1989 June 04 1989 TX0002575359
06/19/1989 June 05 1989 TX0002575754
06/19/1989 June 06 1989 TX0002575755
06/19/1989 June 07 1989 TX0002579670
06/19/1989 June 08 1989 TX0002579668
06/19/1989 June 09 1989 TX0002579666
06/19/1989 June 10 1989 TX0002579669
06/19/1989 June 11 1989 TX0002579667
06/26/1989 June 12 1989 TX0002587737
06/26/1989 June 13 1989 TX0002587738
06/26/1989 June 14 1989 TX0002587740
06/26/1989 June 15 1989 TX0002587741
06/26/1989 June 16 1989 TX0002587742
06/26/1989 June 17 1989 TX0002587733
06/26/1989 June 18 1989 TX0002619649
06/30/1989 June 19 1989 TX0002639643
06/30/1989 June 20 1989 TX0002639642
06/30/1989 June 21 1989 TX0002639641
06/30/1989 June 22 1989 TX0002639640
06/30/1989 June 23 1989 TX0002639639
06/30/1989 June 24 1989 TX0002639638
06/30/1989 June 25 1989 TX0002608749
07/10/1989 June 26 1989 TX0002608792
07/10/1989 June 27 1989 TX0002608791
07/10/1989 June 28 1989 TX0002608708
07/10/1989 June 29 1989 TX0002608707
07/10/1989 June 30 1989 TX0002608706
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 38 of 75

07/10/1989 July 01 1989 TX0002608790


07/10/1989 July 02 1989 TX0002608730
07/13/1989 July 03 1989 TX0002614229
07/13/1989 July 04 1989 TX0002608779
07/13/1989 July 05 1989 TX0002614230
07/13/1989 July 06 1989 TX0002614231
07/13/1989 July 07 1989 TX0002598319
07/13/1989 July 08 1989 TX0002614233
07/13/1989 July 09 1989 TX0002614232
07/20/1989 July 10 1989 TX0002608811
07/20/1989 July 11 1989 TX0002608812
07/20/1989 July 12 1989 TX0002608813
07/20/1989 July 13 1989 TX0002608806
07/20/1989 July 14 1989 TX0002608696
07/20/1989 July 15 1989 TX0002608697
07/20/1989 July 16 1989 TX0002608699
07/28/1989 July 17 1989 TX0002609312
07/28/1989 July 18 1989 TX0002609313
07/28/1989 July 19 1989 TX0002609314
07/28/1989 July 20 1989 TX0002609309
07/28/1989 July 21 1989 TX0002609310
07/28/1989 July 22 1989 TX0002609311
07/28/1989 July 23 1989 TX0002608290
08/11/1989 July 24 1989 TX0002614332
08/11/1989 July 25 1989 TX0002614329
08/11/1989 July 26 1989 TX0002614323
08/11/1989 July 27 1989 TX0002614324
08/11/1989 July 28 1989 TX0002614326
08/11/1989 July 29 1989 TX0002614327
08/11/1989 July 30 1989 TX0002614328
08/11/1989 July 31 1989 TX0002614333
08/11/1989 August 01 1989 TX0002614331
08/11/1989 August 02 1989 TX0002614330
08/11/1989 August 03 1989 TX0002614334
08/11/1989 August 04 1989 TX0002614325
08/22/1989 August 05 1989 TX0002620701
08/22/1989 August 06 1989 TX0002620578
08/22/1989 August 07 1989 TX0002620633
08/22/1989 August 08 1989 TX0002620631
08/22/1989 August 09 1989 TX0002620632
08/22/1989 August 10 1989 TX0002620702
08/22/1989 August 11 1989 TX0002620703
08/22/1989 August 12 1989 TX0002620704
08/22/1989 August 13 1989 TX0002625417
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 39 of 75

08/25/1989 August 14 1989 TX0002620668


08/25/1989 August 15 1989 TX0002620669
08/25/1989 August 16 1989 TX0002620705
08/25/1989 August 17 1989 TX0002625416
08/25/1989 August 18 1989 TX0002620670
08/25/1989 August 19 1989 TX0002620666
08/25/1989 August 20 1989 TX0002620675
08/31/1989 August 21 1989 TX0002625376
08/31/1989 August 22 1989 TX0002623676
08/31/1989 August 23 1989 TX0002623675
08/31/1989 August 24 1989 TX0002625379
08/31/1989 August 25 1989 TX0002625378
08/31/1989 August 26 1989 TX0002625377
08/31/1989 August 27 1989 TX0002623678
09/11/1989 August 28 1989 TX0002632115
09/11/1989 August 29 1989 TX0002632116
09/11/1989 August 30 1989 TX0002632117
09/11/1989 August 31 1989 TX0002632148
09/11/1989 September 01 1989 TX0002632149
09/11/1989 September 02 1989 TX0002632125
09/11/1989 September 03 1989 TX0002632150
09/21/1989 September 04 1989 TX0002647102
09/21/1989 September 05 1989 TX0002647103
09/21/1989 September 06 1989 TX0002647108
09/21/1989 September 07 1989 TX0002647109
09/21/1989 September 08 1989 TX0002647099
09/21/1989 September 09 1989 TX0002647107
09/21/1989 September 10 1989 TX0002647098
09/20/1989 September 11 1989 TX0002643191
09/20/1989 September 12 1989 TX0002643192
09/20/1989 September 13 1989 TX0002643193
09/20/1989 September 14 1989 TX0002643215
09/20/1989 September 15 1989 TX0002643190
09/20/1989 September 16 1989 TX0002643189
09/20/1989 September 17 1989 TX0002644139
09/28/1989 September 18 1989 TX0002649907
09/28/1989 September 19 1989 TX0002649906
09/28/1989 September 20 1989 TX0002649905
09/28/1989 September 21 1989 TX0002649904
09/28/1989 September 22 1989 TX0002649908
09/28/1989 September 23 1989 TX0002649902
09/28/1989 September 24 1989 TX0002649915
10/04/1989 September 25 1989 TX0002644832
10/04/1989 September 26 1989 TX0002644833
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 40 of 75

10/04/1989 September 27 1989 TX0002644834


10/04/1989 September 28 1989 TX0002644807
10/04/1989 September 29 1989 TX0002644808
10/04/1989 September 30 1989 TX0002644812
10/04/1989 October 01 1989 TX0002644835
10/12/1989 October 02 1989 TX0002657632
10/12/1989 October 03 1989 TX0002657633
10/12/1989 October 04 1989 TX0002868000
10/12/1989 October 05 1989 TX0002657634
10/12/1989 October 06 1989 TX0002657629
10/12/1989 October 07 1989 TX0002657630
10/12/1989 October 08 1989 TX0002657631
10/19/1989 October 09 1989 TX0002661367
10/19/1989 October 10 1989 TX0002661366
10/19/1989 October 11 1989 TX0002661370
10/19/1989 October 12 1989 TX0002661369
10/19/1989 October 13 1989 TX0002661368
10/19/1989 October 14 1989 TX0002661379
10/19/1989 October 15 1989 TX0002661365
10/27/1989 October 16 1989 TX0002678660
10/27/1989 October 17 1989 TX0002678659
10/27/1989 October 18 1989 TX0002678657
10/27/1989 October 19 1989 TX0002666979
10/27/1989 October 20 1989 TX0002678658
10/27/1989 October 21 1989 TX0002678662
10/27/1989 October 22 1989 TX0002678665
11/06/1989 October 23 1989 TX0002669207
11/06/1989 October 24 1989 TX0002669208
11/06/1989 October 25 1989 TX0002669209
11/06/1989 October 26 1989 TX0002676694
11/06/1989 October 27 1989 TX0002676693
11/06/1989 October 28 1989 TX0002669210
11/06/1989 October 29 1989 TX0002669211
11/09/1989 October 30 1989 TX0002678076
11/09/1989 October 31 1989 TX0002676654
11/09/1989 November 01 1989 TX0002676653
11/09/1989 November 02 1989 TX0002678068
11/09/1989 November 03 1989 TX0002678074
11/09/1989 November 04 1989 TX0002678075
11/09/1989 November 05 1989 TX0002678045
11/21/1989 November 06 1989 TX0002687689
11/21/1989 November 07 1989 TX0002687690
11/21/1989 November 08 1989 TX0002687691
11/21/1989 November 09 1989 TX0002687692
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 41 of 75

11/21/1989 November 10 1989 TX0002687668


11/21/1989 November 11 1989 TX0002687669
11/21/1989 November 12 1989 TX0002687670
11/29/1989 November 13 1989 TX0002717224
11/29/1989 November 14 1989 TX0002717225
11/29/1989 November 15 1989 TX0002717226
11/29/1989 November 16 1989 TX0002717223
11/29/1989 November 17 1989 TX0002717222
11/29/1989 November 18 1989 TX0002693612
11/29/1989 November 19 1989 TX0002693613
11/30/1989 November 20 1989 TX0002689661
11/30/1989 November 21 1989 TX0002689662
11/30/1989 November 22 1989 TX0002689660
11/30/1989 November 23 1989 TX0002689659
11/30/1989 November 24 1989 TX0002689658
11/30/1989 November 25 1989 TX0002689657
11/30/1989 November 26 1989 TX0002689670
12/12/1989 November 27 1989 TX0002701798
12/12/1989 November 28 1989 TX0002701799
12/12/1989 November 29 1989 TX0002701796
12/12/1989 November 30 1989 TX0002701794
12/12/1989 December 01 1989 TX0002701795
12/12/1989 December 02 1989 TX0002701797
12/12/1989 December 03 1989 TX0002701800
12/18/1989 December 04 1989 TX0002717547
12/18/1989 December 05 1989 TX0002717548
12/18/1989 December 06 1989 TX0002717549
12/18/1989 December 07 1989 TX0002717550
12/18/1989 December 08 1989 TX0002717551
12/18/1989 December 09 1989 TX0002717545
12/18/1989 December 10 1989 TX0002717546
01/04/1990 December 11 1989 TX0002717737
01/04/1990 December 12 1989 TX0002717738
01/04/1990 December 13 1989 TX0002717739
01/04/1990 December 14 1989 TX0002717748
01/04/1990 December 15 1989 TX0002717740
01/04/1990 December 16 1989 TX0002717736
01/04/1990 December 17 1989 TX0002717747
12/28/1989 December 18 1989 TX0002715512
12/28/1989 December 19 1989 TX0002715513
12/28/1989 December 20 1989 TX0002715514
12/28/1989 December 21 1989 TX0002715517
12/28/1989 December 22 1989 TX0002715511
12/28/1989 December 23 1989 TX0002735577
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 42 of 75

12/28/1989 December 24 1989 TX0002715516


01/05/1990 December 25 1989 TX0002717651
01/05/1990 December 26 1989 TX0002717624
01/05/1990 December 27 1989 TX0002717627
01/05/1990 December 28 1989 TX0002717652
01/05/1990 December 29 1989 TX0002717625
01/05/1990 December 30 1989 TX0002717626
01/05/1990 December 31 1989 TX0002717657
01/17/1989 January 01 1990 TX0002725686
01/17/1990 January 02 1990 TX0002725687
01/17/1990 January 03 1990 TX0002725688
01/17/1990 January 04 1990 TX0002725683
01/17/1990 January 05 1990 TX0002725684
01/17/1990 January 06 1990 TX0002725685
01/17/1990 January 07 1990 TX0002704000
01/19/1990 January 08 1990 TX0002726488
01/19/1990 January 09 1990 TX0002726485
01/19/1990 January 10 1990 TX0002726486
01/19/1990 January 11 1990 TX0002726487
01/19/1990 January 12 1990 TX0002726483
01/19/1990 January 13 1990 TX0002726484
01/19/1990 January 14 1990 TX0002726985
01/24/1990 January 15 1990 TX0002736430
01/24/1990 January 16 1990 TX0002736431
01/24/1990 January 17 1990 TX0002736429
01/24/1990 January 18 1990 TX0002736434
01/24/1990 January 19 1990 TX0002736433
01/24/1990 January 20 1990 TX0002736432
01/24/1990 January 21 1990 TX0002736459
02/05/1990 January 22 1990 TX0002742859
02/05/1990 January 23 1990 TX0002742858
02/05/1990 January 24 1990 TX0002742857
02/05/1990 January 25 1990 TX0002742855
02/05/1990 January 26 1990 TX0002742851
02/05/1990 January 27 1990 TX0002742850
02/05/1990 January 28 1990 TX0002742819
02/12/1990 January 29 1990 TX0002745640
02/12/1990 January 30 1990 TX0002743956
02/12/1990 January 31 1990 TX0002745633
02/12/1990 February 01 1990 TX0002745631
02/12/1990 February 02 1990 TX0002743948
02/12/1990 February 03 1990 TX0002743949
02/12/1990 February 04 1990 TX0002743962
02/16/1990 February 05 1990 TX0002750398
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 43 of 75

02/16/1990 February 06 1990 TX0002750409


02/16/1990 February 07 1990 TX0002750408
02/16/1990 February 08 1990 TX0002750329
02/16/1990 February 09 1990 TX0002750335
02/16/1990 February 10 1990 TX0002750322
02/16/1990 February 11 1990 TX0002750323
02/27/1990 February 12 1990 TX0002759939
02/27/1990 February 13 1990 TX0002759935
02/27/1990 February 14 1990 TX0002755454
02/27/1990 February 15 1990 TX0002759941
02/27/1990 February 16 1990 TX0002755455
02/27/1990 February 17 1990 TX0002755450
02/27/1990 February 18 1990 TX0002755449
02/26/1990 February 19 1990 TX0002753308
02/26/1990 February 20 1990 TX0002753307
02/26/1990 February 21 1990 TX0002753304
02/26/1990 February 22 1990 TX0002753305
02/26/1990 February 23 1990 TX0002753310
02/26/1990 February 24 1990 TX0002753299
02/26/1990 February 25 1990 TX0002753354
03/13/1990 February 26 1990 TX0002773489
03/13/1990 February 27 1990 TX0002773494
03/13/1990 February 28 1990 TX0002773493
03/13/1990 March 01 1990 TX0002773526
03/13/1990 March 02 1990 TX0002773492
03/13/1990 March 03 1990 TX0002773531
03/13/1990 March 04 1990 TX0002773530
03/15/1990 March 05 1990 TX0002773323
03/15/1990 March 06 1990 TX0002773326
03/15/1990 March 07 1990 TX0002773325
03/15/1990 March 08 1990 TX0002773327
03/15/1990 March 09 1990 TX0002773331
03/15/1990 March 10 1990 TX0002773324
03/15/1990 March 11 1990 TX0002773320
04/02/1990 March 12 1990 TX0002788223
04/02/1990 March 13 1990 TX0002788224
04/02/1990 March 14 1990 TX0002788225
04/02/1990 March 15 1990 TX0002788226
04/02/1990 March 16 1990 TX0002788227
04/02/1990 March 17 1990 TX0002788283
04/02/1990 March 18 1990 TX0002788284
03/29/1990 March 19 1990 TX0002781696
03/29/1990 March 20 1990 TX0002781704
03/29/1990 March 21 1990 TX0002781702
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 44 of 75

03/29/1990 March 22 1990 TX0002781703


03/29/1990 March 23 1990 TX0002781697
03/29/1990 March 24 1990 TX0002781635
03/29/1990 March 25 1990 TX0002781636
04/05/1990 March 26 1990 TX0002796444
04/05/1990 March 27 1990 TX0002796445
04/05/1990 March 28 1990 TX0002796443
04/05/1990 March 29 1990 TX0002796442
04/05/1990 March 30 1990 TX0002796453
04/05/1990 March 31 1990 TX0002796452
04/05/1990 April 01 1990 TX0002796451
04/11/1990 April 02 1990 TX0002788179
04/11/1990 April 03 1990 TX0002788293
04/11/1990 April 04 1990 TX0002788292
04/11/1990 April 05 1990 TX0002788173
04/11/1990 April 06 1990 TX0002788174
04/11/1990 April 07 1990 TX0002788178
04/19/1990 April 09 1990 TX0002816061
04/19/1990 April 10 1990 TX0002816062
04/19/1990 April 11 1990 TX0002816063
04/19/1990 April 12 1990 TX0002816064
04/19/1990 April 13 1990 TX0002816065
04/19/1990 April 14 1990 TX0002816066
04/19/1990 April 15 1990 TX0002816067
05/01/1990 April 16 1990 TX0002813217
05/01/1990 April 17 1990 TX0002813216
05/01/1990 April 18 1990 TX0002813215
05/01/1990 April 19 1990 TX0002813214
05/01/1990 April 20 1990 TX0002813213
05/01/1990 April 21 1990 TX0002813212
05/01/1990 April 22 1990 TX0002813218
05/09/1990 April 23 1990 TX0002813244
05/09/1990 April 24 1990 TX0002813245
05/09/1990 April 25 1990 TX0002813243
05/09/1990 April 26 1990 TX0002813242
05/09/1990 April 27 1990 TX0002813241
05/09/1990 April 28 1990 TX0002813240
05/09/1990 April 29 1990 TX0002813252
05/10/1990 April 30 1990 TX0002818780
05/10/1990 May 01 1990 TX0002818779
05/10/1990 May 02 1990 TX0002818728
05/10/1990 May 03 1990 TX0002818785
05/10/1990 May 04 1990 TX0002818787
05/10/1990 May 05 1990 TX0002818786
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 45 of 75

05/10/1990 May 06 1990 TX0002818809


05/23/1990 May 07 1990 TX0002834167
05/23/1990 May 08 1990 TX0002834164
05/23/1990 May 09 1990 TX0002834170
05/23/1990 May 10 1990 TX0002834166
05/23/1990 May 11 1990 TX0002830563
05/23/1990 May 12 1990 TX0002830564
05/23/1990 May 13 1990 TX0002830561
05/23/1990 May 14 1990 TX0002834169
05/23/1990 May 15 1990 TX0002830559
05/23/1990 May 16 1990 TX0002830560
05/23/1990 May 17 1990 TX0002830558
05/23/1990 May 18 1990 TX0002834171
05/23/1990 May 19 1990 TX0002834168
05/23/1990 May 20 1990 TX0002830557
05/31/1990 May 21 1990 TX0002844143
05/31/1990 May 22 1990 TX0002848283
05/31/1990 May 23 1990 TX0002830594
05/31/1990 May 24 1990 TX0002830589
05/31/1990 May 25 1990 TX0002830588
05/31/1990 May 26 1990 TX0002830586
05/31/1990 May 27 1990 TX0002830587
06/11/1990 May 28 1990 TX0002849149
06/11/1990 May 29 1990 TX0002849148
06/11/1990 May 30 1990 TX0002849147
06/11/1990 May 31 1990 TX0002849146
06/11/1990 June 01 1990 TX0002849236
06/11/1990 June 02 1990 TX0002845914
06/11/1990 June 03 1990 TX0002828127
06/14/1990 June 04 1990 TX0002844223
06/14/1990 June 05 1990 TX0002844224
06/14/1990 June 06 1990 TX0002840959
06/14/1990 June 07 1990 TX0002840960
06/14/1990 June 08 1990 TX0002844228
06/14/1990 June 09 1990 TX0002844226
06/14/1990 June 10 1990 TX0002844225
06/21/1990 June 11 1990 TX0002844277
06/21/1990 June 12 1990 TX0002841088
06/21/1990 June 13 1990 TX0002841087
06/21/1990 June 14 1990 TX0002846757
06/21/1990 June 15 1990 TX0002844278
06/21/1990 June 16 1990 TX0002844276
06/21/1990 June 17 1990 TX0002844275
06/29/1990 June 18 1990 TX0002844213
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 46 of 75

06/29/1990 June 19 1990 TX0002844212


06/29/1990 June 20 1990 TX0002896201
06/29/1990 June 21 1990 TX0002844211
06/29/1990 June 22 1990 TX0002844217
06/29/1990 June 23 1990 TX0002844214
06/29/1990 June 24 1990 TX0002844215
07/05/1990 June 25 1990 TX0002857509
07/05/1990 June 26 1990 TX0002842454
07/05/1990 June 27 1990 TX0002841921
07/05/1990 June 28 1990 TX0002841925
07/05/1990 June 29 1990 TX0002841927
07/05/1990 June 30 1990 TX0002841924
07/05/1990 July 01 1990 TX0002842455
07/13/1990 July 02 1990 TX0002794417
07/13/1990 July 03 1990 TX0002794408
07/13/1990 July 04 1990 TX0002794409
07/13/1990 July 05 1990 TX0002794410
07/13/1990 July 06 1990 TX0002842435
07/13/1990 July 07 1990 TX0002842434
07/13/1990 July 08 1990 TX0002842433
07/23/1990 July 09 1990 TX0002849235
07/23/1990 July 10 1990 TX0002849174
07/23/1990 July 11 1990 TX0002849175
07/23/1990 July 12 1990 TX0002849232
07/23/1990 July 13 1990 TX0002849173
07/23/1990 July 14 1990 TX0002849177
07/23/1990 July 15 1990 TX0002849176
07/31/1990 July 16 1990 TX0002865539
07/31/1990 July 17 1990 TX0002865533
07/31/1990 July 18 1990 TX0002865534
07/31/1990 July 19 1990 TX0002865535
07/31/1990 July 20 1990 TX0002865532
07/31/1990 July 21 1990 TX0002865536
07/31/1990 July 22 1990 TX0002865540
08/03/1990 July 23 1990 TX0002858813
08/03/1990 July 24 1990 TX0002858812
08/03/1990 July 25 1990 TX0002858811
08/03/1990 July 26 1990 TX0002858799
08/03/1990 July 27 1990 TX0002858803
08/03/1990 July 28 1990 TX0002858802
08/03/1990 July 29 1990 TX0002858796
08/07/1990 July 30 1990 TX0002862328
08/07/1990 July 31 1990 TX0002862311
08/07/1990 August 01 1990 TX0002862309
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 47 of 75

08/07/1990 August 02 1990 TX0002862310


08/07/1990 August 03 1990 TX0002862308
08/07/1990 August 04 1990 TX0002865111
08/07/1990 August 05 1990 TX0002862327
08/15/1990 August 06 1990 TX0002873563
08/15/1990 August 07 1990 TX0002873565
08/15/1990 August 08 1990 TX0002873564
08/15/1990 August 09 1990 TX0002873566
08/15/1990 August 10 1990 TX0002873604
08/15/1990 August 11 1990 TX0002873569
08/15/1990 August 12 1990 TX0002873568
08/28/1990 August 13 1990 TX0002889416
08/28/1990 August 14 1990 TX0002889415
08/28/1990 August 15 1990 TX0002889413
08/28/1990 August 16 1990 TX0002889409
08/28/1990 August 17 1990 TX0002889402
08/28/1990 August 18 1990 TX0002889418
08/28/1990 August 19 1990 TX0002889410
08/28/1990 August 20 1990 TX0002889411
08/28/1990 August 21 1990 TX0002889419
08/28/1990 August 22 1990 TX0002889421
08/28/1990 August 23 1990 TX0002889420
09/14/1990 August 24 1990 TX0002891485
09/14/1990 August 25 1990 TX0002891484
10/01/1990 August 26 1990 TX0002904347
09/14/1990 August 27 1990 TX0002897779
09/14/1990 August 28 1990 TX0002897778
09/14/1990 August 29 1990 TX0002896189
09/14/1990 August 30 1990 TX0002896195
09/14/1990 August 31 1990 TX0002896196
09/14/1990 September 01 1990 TX0002896192
09/14/1990 September 02 1990 TX0002897777
09/14/1990 September 03 1990 TX0002897831
09/14/1990 September 04 1990 TX0002897833
09/14/1990 September 05 1990 TX0002897832
09/14/1990 September 06 1990 TX0002897836
09/14/1990 September 07 1990 TX0002897834
09/14/1990 September 08 1990 TX0002896194
09/14/1990 September 09 1990 TX0002897827
09/24/1990 September 10 1990 TX0002908577
09/24/1990 September 11 1990 TX0002908578
09/24/1990 September 12 1990 TX0002905226
09/24/1990 September 13 1990 TX0002905227
09/24/1990 September 14 1990 TX0002905223
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 48 of 75

09/24/1990 September 15 1990 TX0002905224


09/24/1990 September 16 1990 TX0002905260
10/01/1990 September 17 1990 TX0002904346
10/01/1990 September 18 1990 TX0002904345
10/01/1990 September 19 1990 TX0002918424
10/01/1990 September 20 1990 TX0002908576
10/01/1990 September 21 1990 TX0002904282
10/01/1990 September 22 1990 TX0002904283
10/01/1990 September 23 1990 TX0002904350
10/03/1990 September 24 1990 TX0002911038
10/03/1990 September 25 1990 TX0002911037
10/03/1990 September 26 1990 TX0002911036
10/03/1990 September 27 1990 TX0002918361
10/03/1990 September 28 1990 TX0002918362
10/03/1990 September 29 1990 TX0002918359
10/03/1990 September 30 1990 TX0002904280
10/17/1990 October 01 1990 TX0002924456
10/17/1990 October 02 1990 TX0002924455
10/17/1990 October 03 1990 TX0002924457
10/17/1990 October 04 1990 TX0002924458
10/17/1990 October 05 1990 TX0002924459
10/17/1990 October 06 1990 TX0002924523
10/17/1990 October 07 1990 TX0002924465
10/18/1990 October 08 1990 TX0002923141
10/18/1990 October 09 1990 TX0002923142
10/18/1990 October 10 1990 TX0002923143
10/18/1990 October 11 1990 TX0002923144
10/18/1990 October 12 1990 TX0002923139
10/18/1990 October 13 1990 TX0002923145
10/18/1990 October 14 1990 TX0002923140
10/30/1990 October 15 1990 TX0002924774
10/30/1990 October 16 1990 TX0002919900
10/30/1990 October 17 1990 TX0002919902
10/30/1990 October 18 1990 TX0002919903
10/30/1990 October 19 1990 TX0002919904
10/30/1990 October 20 1990 TX0002919905
10/30/1990 October 21 1990 TX0002924773
11/01/1990 October 22 1990 TX0002922013
11/01/1990 October 23 1990 TX0002922012
11/01/1990 October 24 1990 TX0002922010
11/01/1990 October 25 1990 TX0002922011
11/01/1990 October 26 1990 TX0002922009
11/01/1990 October 27 1990 TX0002922008
11/01/1990 October 28 1990 TX0002922021
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 49 of 75

11/07/1990 October 29 1990 TX0002934711


11/07/1990 October 30 1990 TX0002934707
11/07/1990 October 31 1990 TX0002934706
11/07/1990 November 01 1990 TX0002934705
11/07/1990 November 02 1990 TX0002934709
11/07/1990 November 03 1990 TX0002934708
11/07/1990 November 04 1990 TX0002934713
11/20/1990 November 05 1990 TX0002949302
11/20/1990 November 06 1990 TX0002949301
11/20/1990 November 07 1990 TX0002949300
11/20/1990 November 08 1990 TX0002949305
11/20/1990 November 09 1990 TX0002949299
11/20/1990 November 10 1990 TX0002949298
11/20/1990 November 11 1990 TX0002948830
11/27/1990 November 12 1990 TX0002957295
11/27/1990 November 13 1990 TX0002957294
11/27/1990 November 14 1990 TX0002957293
11/27/1990 November 15 1990 TX0002957296
11/27/1990 November 16 1990 TX0002959750
11/27/1990 November 17 1990 TX0002959751
11/27/1990 November 18 1990 TX0002960063
12/04/1990 November 19 1990 TX0002936572
12/04/1990 November 20 1990 TX0002937648
12/04/1990 November 21 1990 TX0002937649
12/04/1990 November 22 1990 TX0002936574
12/04/1990 November 23 1990 TX0002936573
12/04/1990 November 24 1990 TX0002949391
12/04/1990 November 25 1990 TX0002958004
12/13/1990 December 03 1990 TX0002957645
12/13/1990 December 04 1990 TX0002957644
12/13/1990 December 05 1990 TX0002957966
12/13/1990 December 06 1990 TX0002957967
12/13/1990 December 07 1990 TX0002957965
12/13/1990 December 08 1990 TX0002957964
12/13/1990 December 09 1990 TX0002957650
12/24/1990 December 10 1990 TX0002968997
12/24/1990 December 11 1990 TX0002968998
12/24/1990 December 13 1990 TX0002969147
12/24/1990 December 14 1990 TX0002969145
12/24/1990 December 15 1990 TX0002968994
12/24/1990 December 16 1990 TX0002969119
01/02/1991 December 17 1990 TX0002971143
01/02/1991 December 18 1990 TX0002969129
01/02/1991 December 19 1990 TX0002969125
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 50 of 75

01/02/1991 December 20 1990 TX0002969135


01/02/1991 December 21 1990 TX0002969134
01/02/1991 December 22 1990 TX0002969133
01/02/1991 December 23 1990 TX0002969128
01/02/1991 December 24 1990 TX0002969131
01/02/1991 December 25 1990 TX0002969132
01/02/1991 December 26 1990 TX0002969130
01/14/1991 December 27 1990 TX0002986429
01/14/1991 December 28 1990 TX0002986428
01/14/1991 December 29 1990 TX0002986427
01/14/1991 December 30 1990 TX0002986426
01/14/1991 December 31 1990 TX0002986430
01/14/1991 January 01 1991 TX0002986431
01/14/1991 January 02 1991 TX0003039238
01/14/1991 January 03 1991 TX0002986432
01/14/1991 January 04 1991 TX0002986433
01/24/1991 January 05 1991 TX0002990585
01/24/1991 January 06 1991 TX0002990583
01/24/1991 January 07 1991 TX0002990584
01/24/1991 January 08 1991 TX0002990754
01/24/1991 January 09 1991 TX0002990744
01/24/1991 January 10 1991 TX0002990745
01/24/1991 January 11 1991 TX0002990743
01/24/1991 January 12 1991 TX0002990753
01/24/1991 January 13 1991 TX0002991389
01/29/1991 January 14 1991 TX0002990756
01/29/1991 January 15 1991 TX0002990757
01/29/1991 January 16 1991 TX0002990760
01/29/1991 January 17 1991 TX0002990761
01/29/1991 January 18 1991 TX0002990746
01/29/1991 January 19 1991 TX0002989003
01/29/1991 January 20 1991 TX0002989004
02/07/1991 January 21 1991 TX0002998609
02/07/1991 January 22 1991 TX0002998610
02/07/1991 January 24 1991 TX0003002901
02/07/1991 January 25 1991 TX0002998492
02/07/1991 January 26 1991 TX0002998491
02/07/1991 January 27 1991 TX0003002840
02/11/1991 January 28 1991 TX0003002869
02/11/1991 January 29 1991 TX0002995045
02/11/1991 January 30 1991 TX0003004169
02/11/1991 January 31 1991 TX0003002868
02/11/1991 February 01 1991 TX0003011610
02/11/1991 February 02 1991 TX0003011608
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 51 of 75

02/11/1991 February 03 1991 TX0003011609


02/19/1991 February 04 1991 TX0003008364
02/19/1991 February 05 1991 TX0003019333
02/19/1991 February 06 1991 TX0003008359
02/19/1991 February 07 1991 TX0003008360
02/19/1991 February 08 1991 TX0003008358
02/19/1991 February 09 1991 TX0003008367
02/19/1991 February 10 1991 TX0003011672
02/26/1991 February 11 1991 TX0003015092
02/26/1991 February 12 1991 TX0003015089
02/26/1991 February 13 1991 TX0003015090
02/26/1991 February 14 1991 TX0003015093
02/26/1991 February 15 1991 TX0003015094
02/26/1991 February 16 1991 TX0003015103
02/26/1991 February 17 1991 TX0003019437
03/05/1991 February 18 1991 TX0003019162
03/05/1991 February 19 1991 TX0003019159
03/05/1991 February 20 1991 TX0003019158
03/05/1991 February 21 1991 TX0003019166
03/05/1991 February 22 1991 TX0003019129
03/05/1991 February 23 1991 TX0003019165
03/05/1991 February 24 1991 TX0003019130
03/08/1991 February 25 1991 TX0003048512
03/08/1991 February 26 1991 TX0003048510
03/08/1991 February 27 1991 TX0003048511
03/08/1991 February 28 1991 TX0003015846
03/08/1991 March 01 1991 TX0003019425
03/08/1991 March 02 1991 TX0003019424
03/08/1991 March 03 1991 TX0003019423
03/22/1991 March 04 1991 TX0003039303
03/22/1991 March 05 1991 TX0003074431
03/22/1991 March 06 1991 TX0003039304
03/22/1991 March 07 1991 TX0003039305
03/22/1991 March 08 1991 TX0003030517
03/22/1991 March 09 1991 TX0003030516
03/22/1991 March 10 1991 TX0003030520
03/25/1991 March 11 1991 TX0003039220
03/25/1991 March 12 1991 TX0003033432
03/25/1991 March 13 1991 TX0003033431
03/25/1991 March 14 1991 TX0003030697
03/25/1991 March 15 1991 TX0003039183
03/25/1991 March 16 1991 TX0003030679
03/25/1991 March 17 1991 TX0003060672
04/05/1991 March 18 1991 TX0003033421
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 52 of 75

04/05/1991 March 19 1991 TX0003033420


04/05/1991 March 20 1991 TX0003033422
04/05/1991 March 21 1991 TX0003039273
04/05/1991 March 22 1991 TX0003039274
04/05/1991 March 23 1991 TX0003039275
04/05/1991 March 24 1991 TX0003039272
04/11/1991 March 25 1991 TX0003040965
04/11/1991 March 26 1991 TX0003040966
04/11/1991 March 27 1991 TX0003040962
04/11/1991 March 28 1991 TX0003040960
04/11/1991 March 29 1991 TX0003040963
04/11/1991 March 30 1991 TX0003040951
04/11/1991 March 31 1991 TX0003040964
04/16/1991 April 01 1991 TX0003048472
04/16/1991 April 02 1991 TX0003048483
04/16/1991 April 03 1991 TX0003048471
04/16/1991 April 04 1991 TX0003043740
04/16/1991 April 05 1991 TX0003043738
04/16/1991 April 06 1991 TX0003043739
04/16/1991 April 07 1991 TX0003052527
04/19/2004 April 08 1991 TX0003058484
04/19/1991 April 09 1991 TX0003059190
04/19/1991 April 10 1991 TX0003059192
04/19/2004 April 01 1991 TX0003058482
04/19/2004 April 02 1991 TX0003058480
04/19/2004 April 03 1991 TX0003058481
04/19/1991 April 14 1991 TX0003058479
04/29/1991 April 15 1991 TX0003057398
04/29/1991 April 16 1991 TX0003057399
04/29/1991 April 17 1991 TX0003057400
04/29/1991 April 18 1991 TX0003057395
04/29/1991 April 19 1991 TX0003057396
04/29/1991 April 20 1991 TX0003057407
04/29/1991 April 21 1991 TX0003057408
05/07/1991 April 22 1991 TX0003062048
05/07/1991 April 23 1991 TX0003069728
05/07/1991 April 24 1991 TX0003062047
05/07/1991 April 25 1991 TX0003069729
05/07/1991 April 26 1991 TX0003069738
05/13/1991 April 27 1991 TX0003071221
05/13/1991 April 28 1991 TX0003074512
05/13/1991 April 29 1991 TX0003071220
05/13/1991 April 30 1991 TX0003071219
05/13/1991 May 01 1991 TX0003071218
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 53 of 75

05/13/1991 May 02 1991 TX0003071217


05/13/1991 May 03 1991 TX0003071222
05/13/1991 May 04 1991 TX0003071209
05/13/1991 May 05 1991 TX0003071224
05/16/2005 May 06 1991 TX0003087704
05/16/1991 May 07 1991 TX0003069806
05/16/1991 May 08 1991 TX0003069807
05/16/1991 May 09 1991 TX0003069805
05/16/1991 May 10 1991 TX0003062055
05/16/1991 May 11 1991 TX0003062054
05/16/1991 May 12 1991 TX0003073604
05/24/1991 May 13 1991 TX0003074517
05/24/1991 May 14 1991 TX0003074479
05/24/1991 May 15 1991 TX0003074518
05/24/1991 May 16 1991 TX0003074478
05/24/1991 May 17 1991 TX0003074474
05/24/1991 May 18 1991 TX0003074519
05/24/1991 May 19 1991 TX0003074475
06/03/1991 May 20 1991 TX0003074204
06/03/1991 May 21 1991 TX0003074999
06/03/1991 May 22 1991 TX0003074998
06/03/1991 May 23 1991 TX0003074211
06/03/1991 May 24 1991 TX0003074212
06/03/1991 May 25 1991 TX0003074203
06/03/1991 May 26 1991 TX0003074210
06/06/1991 May 27 1991 TX0003075015
06/06/1991 May 28 1991 TX0003076938
06/06/1991 May 29 1991 TX0003076948
06/06/1991 May 30 1991 TX0003076945
06/06/1991 May 31 1991 TX0003076943
06/06/1991 June 01 1991 TX0003076941
06/06/1991 June 02 1991 TX0003075016
06/12/1991 June 03 1991 TX0003092888
06/12/1991 June 04 1991 TX0003092890
06/12/1991 June 05 1991 TX0003084102
06/12/1991 June 06 1991 TX0003092889
06/12/1991 June 07 1991 TX0003092886
06/12/1991 June 08 1991 TX0003092898
06/12/1991 June 09 1991 TX0003092892
06/24/1991 June 10 1991 TX0003088038
06/24/1991 June 11 1991 TX0003088034
06/24/1991 June 12 1991 TX0003088039
06/24/1991 June 13 1991 TX0003088040
06/24/1991 June 14 1991 TX0003088036
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 54 of 75

06/24/1991 June 15 1991 TX0003088037


06/24/1991 June 16 1991 TX0003088035
07/01/1991 June 17 1991 TX0003097600
07/01/1991 June 18 1991 TX0003097599
07/01/1991 June 19 1991 TX0003094360
07/01/1991 June 20 1991 TX0003094361
07/01/1991 June 21 1991 TX0003097601
07/01/1991 June 22 1991 TX0003094362
07/01/1991 June 23 1991 TX0003095610
07/05/1991 June 24 1991 TX0003092915
07/05/1991 June 25 1991 TX0003092916
07/05/1991 June 26 1991 TX0003092917
07/05/1991 June 27 1991 TX0003092913
07/05/1991 June 28 1991 TX0003092914
07/05/1991 June 29 1991 TX0003092911
07/05/1991 June 30 1991 TX0003092912
07/15/1991 July 01 1991 TX0003105458
07/15/1991 July 02 1991 TX0003105459
07/15/1991 July 03 1991 TX0003105460
07/15/1991 July 04 1991 TX0003105461
07/15/1991 July 05 1991 TX0003105462
07/15/1991 July 06 1991 TX0003105463
07/15/1991 July 07 1991 TX0003105457
07/23/1991 July 08 1991 TX0003102503
07/23/1991 July 09 1991 TX0003102502
07/23/1991 July 10 1991 TX0003102501
07/23/1991 July 11 1991 TX0003102500
07/23/1991 July 12 1991 TX0003102504
07/23/1991 July 13 1991 TX0003102498
07/23/1991 July 14 1991 TX0003102499
07/29/1991 July 15 1991 TX0003105504
07/29/1991 July 16 1991 TX0003105501
07/29/1991 July 17 1991 TX0003105519
07/29/1991 July 18 1991 TX0003105520
07/29/1991 July 19 1991 TX0003105500
07/29/1991 July 20 1991 TX0003105521
07/29/1991 July 21 1991 TX0003110265
08/05/1991 July 22 1991 TX0003115242
08/05/1991 July 24 1991 TX0003115241
08/05/1991 July 25 1991 TX0003115215
08/05/1991 July 26 1991 TX0003115208
08/05/1991 July 27 1991 TX0003115207
08/05/1991 July 28 1991 TX0003115211
08/08/1991 July 29 1991 TX0003121792
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 55 of 75

08/08/1991 July 30 1991 TX0003121793


08/08/1991 July 31 1991 TX0003121790
08/08/1991 August 01 1991 TX0003121791
08/08/1991 August 02 1991 TX0003121797
08/08/1991 August 03 1991 TX0003121796
08/08/1991 August 04 1991 TX0003121783
08/19/1991 August 05 1991 TX0003126931
08/19/1991 August 06 1991 TX0003126930
08/19/1991 August 07 1991 TX0003126928
08/19/1991 August 08 1991 TX0003126929
08/19/1991 August 09 1991 TX0003197599
08/19/1991 August 10 1991 TX0003126038
08/19/1991 August 11 1991 TX0003126927
08/21/1991 August 12 1991 TX0003126019
08/21/1991 August 13 1991 TX0003126020
08/21/1991 August 14 1991 TX0003126015
08/21/1991 August 15 1991 TX0003126016
08/21/1991 August 16 1991 TX0003126017
08/21/1991 August 17 1991 TX0003126018
08/21/1991 August 18 1991 TX0003126014
09/04/1991 August 19 1991 TX0003142961
09/04/1991 August 20 1991 TX0003142952
09/04/1991 August 21 1991 TX0003142953
09/04/1991 August 22 1991 TX0003142960
09/04/1991 August 23 1991 TX0003142963
09/04/1991 August 24 1991 TX0003142962
09/04/1991 August 25 1991 TX0003143752
09/09/1991 August 26 1991 TX0003143683
09/09/1991 August 27 1991 TX0003143686
09/09/1991 August 28 1991 TX0003143690
09/09/1991 August 29 1991 TX0003143685
09/09/1991 August 30 1991 TX0003143763
09/09/1991 August 31 1991 TX0003143762
09/09/1991 September 01 1991 TX0003143761
09/19/1991 September 02 1991 TX0003143753
09/19/1991 September 03 1991 TX0003188869
09/19/1991 September 04 1991 TX0003143754
09/19/1991 September 05 1991 TX0003143756
09/19/1991 September 06 1991 TX0003142958
09/19/1991 September 07 1991 TX0003142957
09/19/1991 September 08 1991 TX0003143712
10/18/1991 September 09 1991 TX0003173244
09/25/1991 September 10 1991 TX0003151395
09/25/1991 September 11 1991 TX0003151396
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 56 of 75

09/25/1991 September 12 1991 TX0003151397


10/18/1991 September 13 1991 TX0003163014
10/18/1991 September 14 1991 TX0003173258
10/18/1991 September 15 1991 TX0003173243
10/18/1991 September 16 1991 TX0003173257
10/18/1991 September 17 1991 TX0003163019
10/18/1991 September 18 1991 TX0003163017
10/18/1991 September 19 1991 TX0003163020
10/18/1991 September 20 1991 TX0003163018
10/18/1991 September 21 1991 TX0003173252
10/18/1991 September 22 1991 TX0003163001
10/18/1991 September 23 1991 TX0003173259
10/18/1991 September 24 1991 TX0003173249
10/18/1991 September 25 1991 TX0003173250
10/18/1991 September 26 1991 TX0003173248
10/18/1991 September 27 1991 TX0003173247
10/18/1991 September 28 1991 TX0003173251
10/18/1991 September 29 1991 TX0003163002
10/18/1991 September 30 1991 TX0003173246
10/18/1991 October 01 1991 TX0003173242
10/18/1991 October 02 1991 TX0003173245
10/18/1991 October 03 1991 TX0003163000
10/18/1991 October 04 1991 TX0003173256
10/18/1991 October 05 1991 TX0003173255
10/18/1991 October 06 1991 TX0003163004
10/21/1991 October 07 1991 TX0003165435
10/21/1991 October 08 1991 TX0003165436
10/21/1991 October 09 1991 TX0003165434
10/21/1991 October 10 1991 TX0003165433
10/21/1991 October 11 1991 TX0003165431
10/21/1991 October 12 1991 TX0003165437
10/21/1991 October 13 1991 TX0003165432
11/04/1991 October 14 1991 TX0003174112
11/04/1991 October 15 1991 TX0003174110
11/04/1991 October 16 1991 TX0003174087
11/04/1991 October 17 1991 TX0003174084
11/04/1991 October 18 1991 TX0003174086
11/04/1991 October 19 1991 TX0003174111
11/04/1991 October 20 1991 TX0003174088
10/31/1991 October 21 1991 TX0003202248
10/31/1991 October 22 1991 TX0003202249
10/31/1991 October 23 1991 TX0003202245
10/31/1991 October 24 1991 TX0003202241
10/31/1991 October 25 1991 TX0003202246
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 57 of 75

10/31/1991 October 26 1991 TX0003202247


10/31/1991 October 27 1991 TX0003202268
11/13/1991 October 28 1991 TX0003185767
11/13/1991 October 29 1991 TX0003185776
11/13/1991 October 30 1991 TX0003185798
11/13/1991 October 31 1991 TX0003185775
11/13/1991 November 01 1991 TX0003185774
11/13/1991 November 02 1991 TX0003185773
11/13/1991 November 03 1991 TX0003185766
11/18/1991 November 04 1991 TX0003185788
11/18/1991 November 05 1991 TX0003185789
11/18/1991 November 06 1991 TX0003185790
11/18/1991 November 07 1991 TX0003185791
11/18/1991 November 08 1991 TX0003185792
11/18/1991 November 09 1991 TX0003185787
11/18/1991 November 10 1991 TX0003185793
11/26/1991 November 11 1991 TX0003191698
11/26/1991 November 12 1991 TX0003191700
11/26/1991 November 13 1991 TX0003191699
11/26/1991 November 14 1991 TX0003191703
11/26/1991 November 15 1991 TX0003191686
11/26/1991 November 16 1991 TX0003191687
11/26/1991 November 17 1991 TX0003191701
12/04/1991 November 18 1991 TX0003202200
12/04/1991 November 19 1991 TX0003202202
12/04/1991 November 20 1991 TX0003202201
12/04/1991 November 21 1991 TX0003202203
12/04/1991 November 22 1991 TX0003202206
12/04/1991 November 23 1991 TX0003202205
12/04/1991 November 24 1991 TX0003202260
12/09/1991 November 25 1991 TX0003202306
12/09/1991 November 26 1991 TX0003202300
12/09/1991 November 27 1991 TX0003202304
12/09/1991 November 28 1991 TX0003202305
12/09/1991 November 29 1991 TX0003202301
12/09/1991 November 30 1991 TX0003202302
12/09/1991 December 01 1991 TX0003202317
12/16/1991 December 02 1991 TX0003212671
12/16/1991 December 03 1991 TX0003212672
12/16/1991 December 04 1991 TX0003212673
12/16/1991 December 05 1991 TX0003212674
12/16/1991 December 06 1991 TX0003212675
12/16/1991 December 07 1991 TX0003209918
12/16/1991 December 08 1991 TX0003212665
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 58 of 75

12/23/1991 December 09 1991 TX0003209860


12/23/1991 December 10 1991 TX0003209984
12/23/1991 December 11 1991 TX0003209859
12/23/1991 December 12 1991 TX0003209863
12/23/1991 December 13 1991 TX0003220945
12/23/1991 December 14 1991 TX0003220908
12/23/1991 December 15 1991 TX0003220946
12/31/1991 December 16 1991 TX0003213488
12/31/1991 December 17 1991 TX0003213489
12/31/1991 December 18 1991 TX0003213509
12/31/1991 December 19 1991 TX0003213510
12/31/1991 December 20 1991 TX0003219799
12/31/1991 December 21 1991 TX0003219721
01/02/1992 December 23 1991 TX0003213484
12/31/1991 December 22 1991 TX0003213434
01/02/1992 December 24 1991 TX0003213487
01/02/1992 December 25 1991 TX0003213490
01/02/1992 December 26 1991 TX0003213492
01/02/1992 December 27 1991 TX0003213485
01/02/1992 December 28 1991 TX0003213460
01/02/1992 December 29 1991 TX0003213501
01/14/1992 December 30 1991 TX0003222262
01/14/1992 December 31 1991 TX0003222261
01/14/1992 January 01 1992 TX0003222170
01/14/1992 January 02 1992 TX0003222255
01/14/1992 January 03 1992 TX0003222256
01/14/1992 January 04 1992 TX0003222260
01/14/1992 January 05 1992 TX0003222263
01/21/1992 January 06 1992 TX0003245968
01/21/1992 January 07 1992 TX0003245969
01/21/1992 January 08 1992 TX0003245970
01/21/1992 January 09 1992 TX0003245972
01/21/1992 January 10 1992 TX0003245971
01/21/1992 January 11 1992 TX0003245973
01/21/1992 January 12 1992 TX0003245966
01/30/1992 January 13 1992 TX0003238583
01/30/1992 January 14 1992 TX0003238579
01/30/1992 January 15 1992 TX0003238580
01/30/1992 January 16 1992 TX0003238581
01/30/1992 January 17 1992 TX0003238586
01/30/1992 January 18 1992 TX0003238582
01/30/1992 January 19 1992 TX0003238458
01/29/1992 January 20 1992 TX0003247419
01/29/1992 January 21 1992 TX0003238688
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 59 of 75

01/29/1992 January 22 1992 TX0003238685


01/29/1992 January 23 1992 TX0003238684
01/29/1992 January 24 1992 TX0003238683
01/29/1992 January 25 1992 TX0003238672
01/29/1992 January 26 1992 TX0003238691
02/18/1992 January 27 1992 TX0003254034
02/18/1992 January 28 1992 TX0003254035
02/18/1992 January 29 1992 TX0003254036
02/18/1992 January 30 1992 TX0003254037
02/18/1992 January 31 1992 TX0003254038
02/18/1992 February 01 1992 TX0003254040
02/18/1992 February 02 1992 TX0003254039
02/18/1992 February 03 1992 TX0003249936
02/18/1992 February 04 1992 TX0003249932
02/18/1992 February 05 1992 TX0003249933
02/18/1992 February 06 1992 TX0003249934
02/18/1992 February 07 1992 TX0003249935
02/18/1992 February 08 1992 TX0003249929
02/18/1992 February 09 1992 TX0003249937
02/26/1992 February 10 1992 TX0003247933
02/26/1992 February 11 1992 TX0003247967
02/26/1992 February 12 1992 TX0003247968
02/26/1992 February 14 1992 TX0003247982
02/26/1992 February 15 1992 TX0003247963
02/26/1992 February 16 1992 TX0003247934
02/26/1992 February 17 1992 TX0003248010
02/26/1992 February 18 1992 TX0003248011
02/26/1992 February 19 1992 TX0003248012
02/26/1992 February 20 1992 TX0003248009
02/26/1992 February 21 1992 TX0003248006
02/26/1992 February 22 1992 TX0003248007
02/26/1992 February 23 1992 TX0003248008
03/11/1992 February 24 1992 TX0003272198
03/11/1992 February 25 1992 TX0003272206
03/11/1992 February 26 1992 TX0003272207
02/27/1992 February 27 1992 TX0003272208
03/11/1992 February 28 1992 TX0003272205
03/11/1992 March 01 1992 TX0003271943
03/16/1992 March 02 1992 TX0003312149
03/16/1992 March 03 1992 TX0003312152
03/16/1992 March 04 1992 TX0003312148
03/16/1992 March 05 1992 TX0003312151
03/16/1992 March 06 1992 TX0003312153
03/16/1992 March 07 1992 TX0003312150
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 60 of 75

03/16/1992 March 08 1992 TX0003312159


03/23/1992 March 09 1992 TX0003272305
03/23/1992 March 10 1992 TX0003272204
03/23/1992 March 11 1992 TX0003272224
03/23/1992 March 12 1992 TX0003272229
03/23/1992 March 13 1992 TX0003272228
03/23/1992 March 14 1992 TX0003272292
03/23/1992 March 15 1992 TX0003272239
03/31/1992 March 16 1992 TX0003275939
03/31/1992 March 17 1992 TX0003275940
03/31/1992 March 18 1992 TX0003275941
03/31/1992 March 19 1992 TX0003275942
03/31/1992 March 20 1992 TX0003278091
03/31/1992 March 21 1992 TX0003278090
03/31/1992 March 22 1992 TX0003275944
04/06/1992 March 23 1992 TX0003275798
04/06/1992 March 24 1992 TX0003275796
04/06/1992 March 25 1992 TX0003275837
04/06/1992 March 26 1992 TX0003275958
04/06/1992 March 27 1992 TX0003275960
04/06/1992 March 28 1992 TX0003275795
04/06/1992 March 29 1992 TX0003275959
04/13/1992 March 30 1992 TX0003275763
04/13/1992 March 31 1992 TX0003275764
04/13/1992 April 01 1992 TX0003275765
04/13/1992 April 02 1992 TX0003275761
04/13/1992 April 03 1992 TX0003275766
04/13/1992 April 04 1992 TX0003275762
04/13/1992 April 05 1992 TX0003275824
04/16/1992 April 06 1992 TX0003295641
04/16/1992 April 07 1992 TX0003295642
04/16/1992 April 08 1992 TX0003295644
04/16/1992 April 09 1992 TX0003295640
04/16/1992 April 10 1992 TX0003295639
04/16/1992 April 11 1992 TX0003295643
04/16/1992 April 12 1992 TX0003295751
05/01/1992 April 13 1992 TX0003296936
05/01/1992 April 14 1992 TX0003296935
05/01/1992 April 15 1992 TX0003296934
05/01/1992 April 16 1992 TX0003296933
05/01/1992 April 17 1992 TX0003296938
05/01/1992 April 18 1992 TX0003296937
05/01/1992 April 19 1992 TX0003296932
05/05/1992 April 20 1992 TX0003303945
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 61 of 75

05/05/1992 April 21 1992 TX0003303948


05/05/1992 April 22 1992 TX0003303946
05/05/1992 April 23 1992 TX0003303947
05/05/1992 April 24 1992 TX0003303943
05/05/1992 April 25 1992 TX0003303944
05/05/1992 April 26 1992 TX0003303941
05/08/1992 April 27 1992 TX0003322948
05/08/1992 April 28 1992 TX0003312214
05/08/1992 April 29 1992 TX0003312217
05/08/1992 April 30 1992 TX0003312218
05/08/1992 May 01 1992 TX0003312216
05/08/1992 May 02 1992 TX0003312215
05/08/1992 May 03 1992 TX0003322949
05/15/1992 May 04 1992 TX0003312314
05/15/1992 May 05 1992 TX0003312315
05/15/1992 May 06 1992 TX0003312316
05/15/1992 May 07 1992 TX0003312317
05/15/1992 May 08 1992 TX0003312318
05/15/1992 May 09 1992 TX0003312312
05/15/1992 May 10 1992 TX0003312311
05/26/1992 May 11 1992 TX0003314859
05/26/1992 May 12 1992 TX0003314860
05/26/1992 May 13 1992 TX0003314861
05/26/1992 May 14 1992 TX0003314895
05/26/1992 May 15 1992 TX0003314896
05/26/1992 May 16 1992 TX0003314890
05/26/1992 May 17 1992 TX0003319271
06/03/1992 May 18 1992 TX0003336504
06/03/1992 May 19 1992 TX0003322921
06/03/1992 May 20 1992 TX0003319498
06/03/1992 May 21 1992 TX0003319559
06/03/1992 May 22 1992 TX0003319553
06/03/1992 May 23 1992 TX0003319550
06/03/1992 May 24 1992 TX0003319549
06/04/1992 May 25 1992 TX0003319365
06/04/1992 May 26 1992 TX0003319366
06/04/1992 May 27 1992 TX0003319367
06/04/1992 May 28 1992 TX0003319368
06/04/1992 May 29 1992 TX0003321095
06/04/1992 May 30 1992 TX0003319370
06/04/1992 May 31 1992 TX0003319369
06/17/1992 June 01 1992 TX0003331131
06/17/1992 June 02 1992 TX0003331132
06/17/1992 June 03 1992 TX0003331133
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 62 of 75

06/17/1992 June 04 1992 TX0003331129


06/17/1992 June 05 1992 TX0003331128
06/17/1992 June 06 1992 TX0003331140
06/17/1992 June 07 1992 TX0003331111
06/18/1992 June 08 1992 TX0003331107
06/18/1992 June 09 1992 TX0003331108
06/18/1992 June 10 1992 TX0003331109
06/18/1992 June 11 1992 TX0003331103
06/18/1992 June 12 1992 TX0003331102
06/18/1992 June 13 1992 TX0003331101
06/18/1992 June 14 1992 TX0003331100
06/30/1992 June 15 1992 TX0003336515
06/30/1992 June 16 1992 TX0003336510
06/30/1992 June 17 1992 TX0003336509
06/30/1992 June 18 1992 TX0003336508
06/30/1992 June 19 1992 TX0003336507
06/30/1992 June 20 1992 TX0003336506
06/30/1992 June 21 1992 TX0003336505
07/09/1992 June 22 1992 TX0003343202
07/09/1992 June 23 1992 TX0003343204
07/09/1992 June 24 1992 TX0003343203
07/09/1992 June 25 1992 TX0003343205
07/09/1992 June 26 1992 TX0003343237
07/09/1992 June 27 1992 TX0003343206
07/09/1992 June 28 1992 TX0003343236
07/13/1992 June 29 1992 TX0003343166
07/13/1992 June 30 1992 TX0003343165
07/13/1992 July 01 1992 TX0003343186
07/13/1992 July 02 1992 TX0003343167
07/13/1992 July 03 1992 TX0003343168
07/13/1992 July 04 1992 TX0003343169
07/13/1992 July 05 1992 TX0003343170
07/22/1992 July 06 1992 TX0003337182
07/22/1992 July 07 1992 TX0003337181
07/22/1992 July 08 1992 TX0003337180
07/22/1992 July 09 1992 TX0003337175
07/22/1992 July 10 1992 TX0003337174
07/22/1992 July 11 1992 TX0003337173
07/22/1992 July 12 1992 TX0003337172
07/29/1992 July 13 1992 TX0003361661
07/29/1992 July 14 1992 TX0003361659
07/29/1992 July 15 1992 TX0003361662
07/29/1992 July 16 1992 TX0003361663
07/29/1992 July 17 1992 TX0003361665
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 63 of 75

07/29/1992 July 18 1992 TX0003361666


07/29/1992 July 19 1992 TX0003361667
07/30/1992 July 20 1992 TX0003361683
07/30/1992 July 21 1992 TX0003361682
07/30/1992 July 22 1992 TX0003361680
07/30/1992 July 23 1992 TX0003361681
07/30/1992 July 24 1992 TX0003366076
07/30/1992 July 25 1992 TX0003361684
07/30/1992 July 26 1992 TX0003366077
08/14/1992 July 27 1992 TX0003372328
08/14/1992 July 28 1992 TX0003372329
08/14/1992 July 29 1992 TX0003372316
08/14/1992 July 30 1992 TX0003372317
08/14/1992 July 31 1992 TX0003372330
08/14/1992 August 01 1992 TX0003372331
08/14/1992 August 02 1992 TX0003372326
08/21/1992 August 03 1992 TX0003369374
08/21/1992 August 04 1992 TX0003369376
08/21/1992 August 05 1992 TX0003369377
08/21/1992 August 06 1992 TX0003369373
08/21/1992 August 07 1992 TX0003369380
08/21/1992 August 08 1992 TX0003369375
08/21/1992 August 09 1992 TX0003369381
08/27/1992 August 10 1992 TX0003379262
08/21/1992 August 11 1992 TX0003369371
08/21/1992 August 12 1992 TX0003369378
08/21/1992 August 13 1992 TX0003369372
10/19/1992 August 14 1992 TX0003417407
08/27/1992 August 15 1992 TX0003379263
08/27/1992 August 16 1992 TX0003379283
08/27/1992 August 18 1992 TX0003374136
08/27/1992 August 19 1992 TX0003374139
08/27/1992 August 20 1992 TX0003374138
08/27/1992 August 21 1992 TX0003379289
08/27/1992 August 22 1992 TX0003379288
08/27/1992 August 23 1992 TX0003374277
09/10/1992 August 24 1992 TX0003379287
09/10/1992 August 25 1992 TX0003379286
09/10/1992 August 26 1992 TX0003379285
09/10/1992 August 27 1992 TX0003379292
09/10/1992 August 28 1992 TX0003379291
09/10/1992 August 29 1992 TX0003379284
09/10/1992 August 30 1992 TX0003379290
09/14/1992 August 31 1992 TX0003379540
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 64 of 75

09/14/1992 September 01 1992 TX0003417368


09/14/1992 September 02 1992 TX0003379538
09/14/1992 September 03 1992 TX0003379539
09/14/1992 September 04 1992 TX0003417366
09/14/1992 September 05 1992 TX0003417367
09/14/1992 September 06 1992 TX0003417365
09/21/1992 September 07 1992 TX0003388164
09/21/1992 September 08 1992 TX0003388208
09/21/1992 September 09 1992 TX0003388209
09/21/1992 September 10 1992 TX0003388210
09/21/1992 September 11 1992 TX0003388211
09/21/1992 September 12 1992 TX0003388160
09/21/1992 September 13 1992 TX0003388163
09/30/1992 September 14 1992 TX0003417316
09/30/1992 September 15 1992 TX0003417317
09/30/1992 September 16 1992 TX0003417318
09/30/1992 September 17 1992 TX0003417313
09/30/1992 September 18 1992 TX0003417322
09/30/1992 September 19 1992 TX0003417321
09/30/1992 September 20 1992 TX0003397499
10/13/1992 September 21 1992 TX0003417386
10/13/1992 September 22 1992 TX0003417385
10/13/1992 September 23 1992 TX0003417384
10/13/1992 September 24 1992 TX0003417388
10/13/1992 September 25 1992 TX0003417383
10/13/1992 September 26 1992 TX0003417390
10/13/1992 September 27 1992 TX0003417391
10/16/1992 September 28 1992 TX0003428913
10/16/1992 September 29 1992 TX0003428880
10/16/1992 October 01 1992 TX0003428912
10/16/1992 October 02 1992 TX0003428879
10/16/1992 October 03 1992 TX0003428904
10/16/1992 October 04 1992 TX0003412321
10/19/1992 October 05 1992 TX0003412339
10/19/1992 October 06 1992 TX0003412340
10/19/1992 October 07 1992 TX0003412341
10/19/1992 October 08 1992 TX0003412322
10/19/1992 October 09 1992 TX0003412323
10/19/1992 October 10 1992 TX0003412324
10/19/1992 October 11 1992 TX0003412326
10/22/1992 October 12 1992 TX0003417630
10/22/1992 October 13 1992 TX0003417545
10/22/1992 October 14 1992 TX0003417544
10/22/1992 October 15 1992 TX0003417543
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 65 of 75

10/22/1992 October 16 1992 TX0003417542


10/16/1992 September 30 1992 TX0003428881
10/22/1992 October 17 1992 TX0003417541
10/22/1992 October 18 1992 TX0003417546
11/04/1992 October 19 1992 TX0003423960
11/04/1992 October 20 1992 TX0003423958
11/04/1992 October 21 1992 TX0003423961
11/04/1992 October 22 1992 TX0003421627
11/04/1992 October 23 1992 TX0003421433
11/04/1992 October 24 1992 TX0003423959
11/04/1992 October 25 1992 TX0003421626
11/09/1992 October 26 1992 TX0003423987
11/09/1992 October 27 1992 TX0003423986
11/09/1992 October 28 1992 TX0003424019
11/09/1992 October 29 1992 TX0003424020
11/09/1992 October 30 1992 TX0003423976
11/09/1992 October 31 1992 TX0003424018
11/09/1992 November 01 1992 TX0003424017
11/17/1992 November 02 1992 TX0003428925
11/17/1992 November 03 1992 TX0003428924
11/17/1992 November 04 1992 TX0003428923
11/17/1992 November 05 1992 TX0003428922
11/17/1992 November 06 1992 TX0003428921
11/17/1992 November 07 1992 TX0003428920
11/17/1992 November 08 1992 TX0003428919
11/30/1992 November 09 1992 TX0003440570
11/30/1992 November 10 1992 TX0003440571
11/30/1992 November 11 1992 TX0003440572
11/30/1992 November 12 1992 TX0003440568
11/30/1992 November 13 1992 TX0003440569
11/30/1992 November 14 1992 TX0003440566
11/30/1992 November 15 1992 TX0003440567
12/08/1992 November 16 1992 TX0003454800
12/08/1992 November 17 1992 TX0003454801
12/08/1992 November 18 1992 TX0003454825
12/08/1992 November 19 1992 TX0003454799
12/08/1992 November 20 1992 TX0003454797
12/08/1992 November 21 1992 TX0003454798
12/08/1992 November 22 1992 TX0003454796
12/04/1992 November 23 1992 TX0003440597
12/04/1992 November 24 1992 TX0003440601
12/04/1992 November 25 1992 TX0003440600
12/04/1992 November 26 1992 TX0003440599
12/04/1992 November 27 1992 TX0003440598
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 66 of 75

12/04/1992 November 28 1992 TX0003440596


12/04/1992 November 29 1992 TX0003440643
12/16/1992 November 30 1992 TX0003454743
12/16/1992 December 01 1992 TX0003454744
12/16/1992 December 02 1992 TX0003454745
12/16/1992 December 03 1992 TX0003454742
12/16/1992 December 04 1992 TX0003454814
12/16/1992 December 05 1992 TX0003455870
12/16/1992 December 06 1992 TX0003454815
12/29/1992 December 07 1992 TX0003454677
12/29/1992 December 08 1992 TX0003454676
12/29/1992 December 09 1992 TX0003454665
12/29/1992 December 10 1992 TX0003454674
12/29/1992 December 11 1992 TX0003454675
12/29/1992 December 12 1992 TX0003454663
12/29/1992 December 13 1992 TX0003454664
12/28/1992 December 14 1992 TX0003454659
12/28/1992 December 15 1992 TX0003454660
06/24/1993 December 16 1992 TX0003454661
12/28/1992 December 17 1992 TX0003454672
06/24/1993 December 18 1992 TX0003454662
04/23/1993 December 19 1992 TX0003454609
12/28/1992 December 20 1992 TX0003454673
01/07/1993 December 21 1992 TX0003528088
01/07/1993 December 22 1992 TX0003528087
01/07/1993 December 23 1992 TX0003528086
01/07/1993 December 24 1992 TX0003528085
01/07/1993 December 25 1992 TX0003528084
01/07/1993 December 26 1992 TX0003528094
01/07/1993 December 27 1992 TX0003528093
01/07/1993 December 28 1992 TX0003528089
01/07/1993 December 29 1992 TX0003528090
01/07/1993 December 30 1992 TX0003528092
01/07/1993 December 31 1992 TX0003528091
03/19/1993 January 1993 TX0003629602
04/15/1993 February 1993 TX0003539940
05/24/1993 March 1993 TX0003630132
06/21/1993 April 1993 TX0003562106
07/22/1993 May 1993 TX0003744244
08/27/1993 August 1993 TX0003589362
09/03/1993 June 1993 TX0003630231
09/30/1993 July 1993 TX0003694482
10/12/1993 August 1993 TX0003694511
11/26/1993 September 1993 TX0003754615
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 67 of 75

01/18/1994 November 1993 TX0003694410


01/27/1994 October 1993 TX0003754831
02/24/1994 December 1993 TX0003773780
03/11/1994 January 1994 TX0003774343
05/04/1994 February 1994 TX0003774308
05/16/1994 March 1994 TX0003833159
06/24/1994 April 1994 TX0003833268
07/21/1994 May 1994 TX0003848784
08/17/1994 June 1994 TX0003909764
10/07/1994 July 1994 TX0003848891
11/04/1994 August 1994 TX0003946973
11/14/1994 September 1994 TX0003946972
01/04/1995 October 1994 TX0003970253
02/01/1995 November 1994 TX0003950871
02/21/1995 December 1994 TX0004004820
04/10/1995 January 1995 TX0004016572
04/17/1995 February 1995 TX0004013337
05/19/1995 March 1995 TX0004022559
07/10/1995 April 1995 TX0004022856
08/14/1995 May 1995 TX0004101750
09/19/1995 June 1995 TX0004110721
10/20/1995 July 1995 TX0004181142
11/08/1995 August 1995 TX0004124261
12/05/1995 September 1995 TX0004165925
12/26/1995 October 1995 TX0004165970
01/24/1996 November 1995 TX0004156412
02/26/1996 December 1995 TX0004185062
03/25/1996 January 1996 TX0004181116
04/22/1996 February 1996 TX0004204380
05/31/1996 March 1996 TX0004271840
08/19/1996 April 1996 TX0004363121
09/25/1996 June 1996 TX0004336928
09/25/1996 July 1996 TX0004336903
11/19/1996 August 1996 TX0004363123
11/20/1996 September 1996 TX0004536202
12/16/1996 May 1996 TX0004397876
12/23/1996 October 1996 TX0004569487
03/06/1997 November 1996 TX0004434607
03/10/1997 December 1996 TX0004420536
04/07/1997 January 1997 TX0004439686
05/21/1997 February 1997 TX0004468871
06/18/1997 March 1997 TX0004490685
06/18/1997 April 1997 TX0004490681
08/12/1997 May 1997 TX0004518137
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 68 of 75

09/08/1997 June 1997 TX0004538126


10/27/1997 July 1997 TX0004557160
11/20/1997 September 1997 TX0004572889
01/09/1998 October 1997 TX0004602995
02/09/1998 November 1997 TX0004616441
02/19/1998 August 1997 TX0004616423
04/06/1998 December 1997 TX0004637931
04/06/1998 January 1998 TX0004650288
05/28/1998 February 1998 TX0004706128
06/29/1998 March 1998 TX0004711430
08/10/1998 April 1998 TX0004740447
08/13/1998 May 1998 TX0004737867
07/16/1999 June 1998 TX0004938668
07/16/1999 July 1998 TX0004938664
07/16/1999 August 1998 TX0004938669
07/16/1999 September 1998 TX0004938666
07/16/1999 October 1998 TX0004938667
07/16/1999 November 1998 TX0004935315
07/16/1999 December 1998 TX0004938665
07/16/1999 January 1999 TX0004938663
07/16/1999 February 1999 TX0004935341
07/16/1999 March 1999 TX0004938657
07/16/1999 April 1999 TX0004938645
08/27/1999 May 1999 TX0004979410
08/30/1999 June 1999 TX0004979384
09/27/1999 July 1999 TX0004054851
10/28/1999 August 1999 TX0005000308
11/22/1999 September 1999 TX0005022666
01/24/2000 October 1999 TX0005041635
01/24/2000 November 1999 TX0005041634
03/06/2000 December 1999 TX0005052091
03/06/2000 January 2000 TX0005052110
04/10/2000 February 2000 TX0005078457
05/11/2000 March 2000 TX0005093577
07/17/2000 April 2000 TX0005124108
08/17/2000 May 2000 TX0005148199
09/11/2000 July 2000 TX0005198643
09/11/2000 June 2000 TX0005171118
11/13/2000 August 2000 TX0005193127
11/17/2000 September 2000 TX0005209652
01/19/2001 October 2000 TX0005234327
01/29/2001 November 2000 TX0005274375
03/19/2001 December 2000 TX0005271941
04/23/2001 January 2001 TX0005294055
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 69 of 75

04/23/2001 February 2001 TX0005294033


06/21/2001 April 2001 TX0005330788
06/25/2001 March 2001 TX0005330015
08/03/2001 May 2001 TX0005355294
08/24/2001 June 2001 TX0005376999
10/15/2001 July 2001 TX0005405035
01/30/2002 October 2001 TX0005502757
03/04/2002 September 2001 TX0005426586
03/26/2002 November 2001 TX0005562050
04/17/2002 January 2002 TX0005569855
04/22/2002 February 2002 TX0005582069
05/03/2002 August 2001 TX0005569864
05/24/2002 December 2001 TX0005554583
06/24/2002 March 2002 TX0005554637
08/08/2002 April 2002 TX0005582138
08/09/2002 May 2002 TX0005582132
10/15/2002 June 2002 TX0005613710
10/16/2002 July 2002 TX0005600424
11/12/2002 August 2002 TX0005613726
11/25/2002 September 2002 TX0005639690
01/14/2003 October 2002 TX0005654162
02/10/2003 November 2002 TX0005657788
03/25/2003 December 2002 TX0005683862
03/29/2003 December 2003 TX0005921891
04/01/2003 January 2003 TX0005702677
05/01/2003 February 2003 TX0005729461
07/03/2003 March 2003 TX0005760225
07/03/2003 April 2003 TX0005673208
07/30/2003 May 2003 TX0005800575
08/26/2003 June 2003 TX0005800460
10/24/2003 July 2003 TX0005842105
10/28/2003 August 2003 TX0005842108
12/02/2003 September 2003 TX0005878913
01/16/2004 October 2003 TX0005878729
02/17/2004 November 2003 TX0005892021
03/29/2004 January 2004 TX0005922015
05/17/2004 February 2004 TX0005964183
05/24/2004 March 2004 TX0005964178
07/06/2004 April 2004 TX0005989059
07/15/2004 March 2004 TX0006010365
09/09/2004 May 2004 TX0006069406
09/17/2004 June 2004 TX0006069581
10/20/2004 July 2004 TX0006052559
10/20/2004 August 2004 TX0006052556
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 70 of 75

12/06/2004 September 2004 TX0006071958


01/28/2005 October 2004 TX0006103478
02/07/2005 November 2004 TX0006103479
03/04/2005 December 2004 TX0006116181
04/11/2005 January 2005 TX0006128731
06/03/2005 February 2005 TX0006181346
06/24/2005 March 2005 TX0006181370
06/28/2005 April 2005 TX0006181345
08/01/2005 May 2005 TX0006187925
09/13/2005 June 2005 TX0006215781
09/20/2005 July 2005 TX0006222424
10/28/2005 August 2005 TX0006238375
11/23/2005 September 2005 TX0006431433
01/17/2006 October 2005 TX0006285613
01/24/2006 November 2005 TX0006290979
03/27/2006 December 2005 TX0006331174
03/30/2006 January 2006 TX0006326596
05/01/2006 February 2006 TX0006334963
06/20/2006 March 2006 TX0006379160
07/07/2006 April 2006 TX0006417272
08/18/2006 May 2006 TX0006611796
08/31/2006 June 2006 TX0006611797
09/18/2006 July 2006 TX0006431403
11/14/2006 August 2006 TX0006481188
11/28/2006 September 2006 TX0006479988
01/29/2007 October 2006 TX0006511591
01/29/2007 November 2006 TX0006505011
02/16/2007 December 2006 TX0006511609
04/17/2007 January 2007 TX0006550566
06/05/2007 February 2007 TX0006587891
06/06/2007 March 2007 TX0006587863
06/22/2007 April 2007 TX0006587940
08/06/2007 May 2007 TX0006614523
10/05/2007 June 2007 TX0006630465
10/09/2007 July 2007 TX0006630457
10/22/2007 August 2007 TX0006630398
12/02/2007 September 2007 TX0006644183
01/14/2008 October 2007 TX0006644606
01/17/2008 November 2007 TX0006663034
05/05/2008 December 2007 TX0006647202
04/08/2008 January 2008 TX0006662645
04/16/2008 February 2008 TX0006647192
06/16/2008 March 2008 TX0006662404
06/26/2008 April 2008 TX0006662925
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 71 of 75

07/24/2008 May 2008 TX0006661189


08/11/2008 June 2008 TX0006662634
10/06/2008 July 2008 TX0006660567
10/23/2008 August 2008 TX0006664660
11/21/2008 September 2008 TX0006660452
01/29/2009 October 2008 TX0006631926
03/09/2009 November 2008 TX0006679508
03/12/2008 December 2008 TX0006679472
04/16/2009 January 2009 TX0006631550
06/11/2009 February 2009 TX0006681730
06/18/2009 March 2009 TX0006679511
09/14/2009 April 2009 TX0006683998
08/07/2009 May 2009 TX0006685341
11/27/2009 June 2009 TX0006700069
10/13/2009 July 2009 TX0006685673
11/02/2009 August 2009 TX0006700107
11/30/2009 September 2009 TX0006699974
01/01/2010 October 2009 TX0006701541
03/17/2010 November 2009 TX0006702486
05/25/2010 December 2009 TX0006704244
04/12/2010 January 2010 TX0006704036
05/25/2010 February 2010 TX0006704261
07/06/2010 March 2010 TX0006704863
07/02/2010 April 2010 TX0006704874
09/01/2010 May 2010 TX0006705118
10/06/2010 June 2010 TX0006776164
10/06/2010 June 2010 TX0006787584;
10/08/2010 July 2010 TX0006771483
10/22/2010 August 2010 TX0006718509
12/20/2010 September 2010 TX0006771757
01/10/2011 October 2010 TX0006771515
02/22/2011 November 2010 TX0006772975
03/23/2011 December 2010 TX0006772922
04/13/2011 January 2011 TX0006776368
06/13/2011 February 2011 TX0006778315
07/12/2011 March 2011 TX0006787582
08/04/2011 April 2011 TX0006779136
08/03/2011 May 2011 TX0006784582
09/12/2011 June 2011 TX0006784583
07/12/2011 July 2011 TX0006604599
07/11/2011 August 2011 TX0006604598
03/01/2012 September 2011 TX0006787890
05/23/2012 October 2011 TX0006612366
07/05/2012 November 2011 TX0006789366
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 72 of 75

08/17/2012 December 2011 TX0006612368


10/09/2012 February 2012 TX0006540580;
11/19/2012 March 2012 TX0006604600
09/14/2012 January 2012 TX0006612369
12/07/2012 April 2012 TX0007693250
12/26/2012 May 2012 TX0007741913
12/26/2012 June 2012 TX0007741886
02/26/2013 October 2012 TX0007806274
02/26/2013 August 2012 TX0007806252
03/26/2013 September 2012 TX0007806296
03/26/2013 July 2012 TX0007806241
05/09/2013 December 2012 TX0007883233
05/09/2013 November 2012 TX0007883208
07/12/2013 February 2013 TX0007903616
07/12/2013 January 2013 TX0007903591
08/26/2013 April 2013 TX0008003374
08/27/2013 March 2013 TX0008003361
09/26/2013 May 2013 TX0007901978
01/22/2014 July 2013 TX0007875719
01/22/2014 June 2013 TX0007875720
04/07/2014 August 2013 TX0007950929
04/07/2014 September 2013 TX0007886804
05/05/2014 October 2013 TX0008003340
05/05/2014 November 2013 TX0008003354
08/28/2014 December 2013 TX0007966070
08/28/2014 January 2014 TX0007966053
09/23/2014 March 2014 TX0008076799
09/23/2014 February 2014 TX0008076781
10/20/2014 May 2014 TX0007936960
10/20/2014 April 2013 TX0007936954
02/09/2015 July 2014 TX0008152663
02/09/2015 June 2014 TX0008152698
03/16/2015 August 2014 TX0008152566
03/16/2015 September 2014 TX0008152759
05/12/2015 November 2014 TX0008162251
05/12/2015 October 2014 TX0008162628
06/26/2015 January 2015 TX0008180689
06/26/2015 December 2014 TX0008180683
09/03/2015 February 2015 TX0008149322
09/04/2015 March 2015 TX0008149564
10/13/2015 April 2015 TX0008234296
10/13/2015 May 2015 TX0008232331
01/04/2016 June 2015 TX0008247525
01/04/2016 July 2015 TX0008247536
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 73 of 75

02/02/2016 August 2015 TX0008215457


02/02/2016 September 2015 TX0008215332
03/25/2016 November 2015 TX0008256082
03/25/2016 October 2015 TX0008256080
06/06/2016 December 2015 TX0008264020
07/05/2016 February 2016 TX0008371130
07/05/2016 January 2016 TX0008371141
07/07/2016 April 2016 TX0008331424
07/09/2016 March 2016 TX0008331553
09/19/2016 May 2016 TX0008284018
10/18/2016 June 2016 TX0008334468
11/17/2016 July 2016 TX0008342638
12/19/2016 August 2016 TX0008301851
01/13/2017 September 2016 TX0008378334
03/10/2017 October 2016 TX0008342981
04/06/2017 December 2016 TX0008381534
04/07/2017 November 2016 TX0008381531
07/11/2017 March 2017 TX0008402856
07/11/2017 January 2017 TX0008403301
07/20/2017 April 2017 TX0008403280
07/25/2017 February 2017 TX0008467170
08/15/2017 May 2017 TX0008426926
09/29/2017 June 2017 TX0008472549
11/02/2017 July 2017 TX0008473142
11/02/2017 August 2017 TX0008473138
01/02/2018 October 2017 TX0008496749
01/02/2018 September 2017 TX0008496766
02/26/2018 November 2017 TX0008670646
02/26/2018 December 2017 TX0008670662
03/29/2018 January 2018 TX0008532326
04/13/2018 February 2018 TX0008532321
05/18/2018 March 2018 TX0008548153
05/31/2018 April 2018 TX0008548159
06/25/2018 May 2018 TX0008575835
07/19/2018 June 2018 TX0008575864
08/03/2018 July 2018 TX0008581007
09/21/2018 August 2018 TX0008619787
10/11/2018 September 2018 TX0008667496
11/15/2018 October 2018 TX0008667980
12/17/2018 November 2018 TX0008668175
01/18/2019 December 2018 TX0008671358
02/20/2019 January 2019 TX0008700758
03/29/2019 February 2019 TX0008799913
04/09/2019 March 2019 TX0008798400
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 74 of 75

05/03/2019 April 2019 TX0008789889


06/04/2019 May 2019 TX0008793394
07/03/2019 June 2019 TX0008798527
08/06/2019 July 2019 TX0008804787
09/06/2019 August 2019 TX0008804391
10/11/2019 September 2019 TX0008820641
11/13/2019 October 2019 TX0008822353
12/10/2019 November 2019 TX0008829325
01/14/2020 December 2019 TX0008832419
02/21/2020 January 2020 TX0008860609
03/11/2020 February 2020 TX0008861827
04/06/2020 March 2020 TX0008863368
05/06/2020 April 2020 TX0008877261
06/08/2020 May 2020 TX0008884825
07/08/2020 June 2020 TX0008886921
08/06/2020 July 2020 TX0008893594
09/03/2020 August 2020 TX0008901386
10/05/2020 September 2020 TX0008911320
11/04/2020 October 2020 TX0008919627
12/02/2020 November 2020 TX0008923677
01/05/2021 December 2020 TX0008932172
02/03/2021 January 2021 TX0008940957
03/03/2021 February 2021 TX0008955210
04/02/2021 March 2021 TX0008960902
05/04/2021 April 2021 TX0008973196
07/07/2021 June 2021 TX0009292584
08/08/2021 July 2021 TX0009011632
09/07/2021 May 2021 TX0009036853
09/14/2021 August 2021 TX0009033069
10/12/2021 September 2021 TX0009070751
11/09/2021 October 2021 TX0009093718
12/10/2021 November 2021 TX0009112293
01/11/2022 December 2021 TX0009123513
02/16/2022 January 2022 TX0009130381
03/10/2022 February 2022 TX0009140381
04/12/2022 March 2022 TX0009147517
05/26/2022 April 2022 TX0009197706
06/21/2022 May 2022 TX0009170786
07/19/2022 June 2022 TX0009181855
09/03/2022 July 2022 TX0009187861
09/30/2022 August 2022 TX0009198634
10/07/2022 September 2022 TX0009202424
11/10/2022 October 2022 TX0009220792
12/22/2022 November 2022 TX0009254416
Case 1:24-cv-03285 Document 1-2 Filed 04/30/24 Page 75 of 75

01/10/2023 December 2022 TX0009260679


02/02/2023 January 2023 TX0009266515
03/24/2023 February 2023 TX0009276211
05/14/2023 April 2023 TX0009289535
06/12/2023 May 2023 TX0009292889
07/11/2023 June 2023 TX0009301877
07/12/2023 March 2023 TX0009285014
08/15/2023 July 2023 TX0009308785
09/12/2023 August 2023 TX0009320234
10/13/2023 September 2023 TX0009330678
11/17/2023 October 2023 TX0009337283
12/06/2023 November 2023 TX0009345772
01/09/2024 December 2023 TX0009359745
02/12/2024 January 2024 TX0009377905
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 1 of 8

EXHIBIT C
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 2 of 8

ORLANDO SENTINEL
Registration Date Issue Registered (Month/Year) Registration Number
02/01/2000 July 1999 TX0005038651
02/01/2000 August 1999 TX0005038650
02/25/2000 September 1999 TX0005108182
02/25/2000 October 1999 TX0005108181
02/25/2000 November 1999 TX0005108180
03/28/2000 December 1999 TX0005071513
04/24/2000 January 2000 TX0005078816
05/30/2000 February 2000 TX0005108179
07/07/2000 March 2000 TX0005124118
07/10/2000 April 2000 TX0005171848
08/11/2000 May 2000 TX0005164221
09/14/2000 June 2000 TX0005164197
10/16/2000 July 2000 TX0005173606
11/27/2000 August 2000 TX0005193578
02/05/2001 September 2000 TX0005243020
03/28/2001 October 2000 TX0005286674
09/07/2001 January 2001 TX0005388858
07/23/2001 February 2001 TX0005345247
07/23/2001 March 2001 TX0005345236
07/31/2001 April 2001 TX0005404969
09/20/2001 May 2001 TX0005388859
07/17/2001 June 2001 TX0005388874
10/15/2001 July 2001 TX0005433226
02/01/2002 August 2001 TX0005613739
12/21/2001 September 2001 TX0005532037
02/08/2002 October 2001 TX0005516388
05/06/2002 December 2001 TX0005544510
06/13/2002 January 2002 TX0005613266
06/13/2002 February 2002 TX0005613272
06/20/2002 March 2002 TX0005613273
07/11/2002 April 2002 TX0005613265
03/06/2003 November 2002 TX0005809654
08/15/2003 December 2002 TX0005842111
08/15/2003 January 2003 TX0005842112
08/27/2003 February 2003 TX0005809540
08/27/2003 March 2003 TX0005806774
09/08/2003 April 2003 TX0005809523
09/08/2003 May 2003 TX0005809640
09/12/2003 June 2003 TX0005809574
10/28/2003 July 2003 TX0005868368
10/30/2003 August 2003 TX0005922004
04/30/2004 September 2003 TX0005929473
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 3 of 8

05/04/2004 October 2003 TX0005964161


04/30/2004 November 2003 TX0005964871
04/30/2004 December 2003 TX0005964819
04/30/2004 January 2004 TX0005964870
04/30/2004 February 2004 TX0005964876
08/30/2004 March 2004 TX0006018390
08/31/2004 April 2004 TX0006033111
08/31/2004 May 2004 TX0006018388
08/31/2004 June 2004 TX0006018389
10/15/2004 July 2004 TX0006052558
12/07/2004 August 2004 TX0006078201
12/07/2004 September 2004 TX0006066475
01/24/2005 October 2004 TX0006110271
01/25/2005 November 2004 TX0006110269
03/15/2005 December 2004 TX0006128721
04/12/2005 January 2005 TX0006143991
06/21/2005 February 2005 TX0006172137
06/13/2005 March 2005 TX0006172139
07/15/2005 April 2005 TX0006206942
08/12/2005 May 2005 TX0006206943
10/13/2005 July 2005 TX0006210526
11/23/2005 August 2005 TX0006331337
02/09/2006 September 2005 TX0006290931
01/25/2006 October 2005 TX0006331327
02/07/2006 November 2005 TX0006300299
03/13/2006 December 2005 TX0006330103
04/14/2006 January 2006 TX0006340527
05/15/2006 February 2006 TX0006349889
07/03/2006 March 2006 TX0006422079
08/07/2006 April 2006 TX0006611788
08/07/2006 May 2006 TX0006417287
10/20/2006 June 2006 TX0006436511
12/11/2006 August 2006 TX0006469041
12/11/2006 September 2006 TX0006469039
04/06/2007 October 2006 TX0006611927
04/06/2007 November 2006 TX0006614101
04/06/2007 December 2006 TX0006614109
04/06/2007 January 2007 TX0006550553
10/22/2007 April 2007 TX0006630491
10/22/2007 May 2007 TX0006630490
10/22/2007 June 2007 TX0006630489
10/22/2007 July 2007 TX0006630488
12/20/2007 August 2007 TX0006644505
01/17/2008 September 2007 TX0006644608
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 4 of 8

02/04/2008 October 2007 TX0006647569


02/11/2008 November 2007 TX0006647179
05/19/2008 December 2007 TX0006647047
05/19/2008 January 2008 TX0006647053
05/19/2008 February 2008 TX0006647172
08/14/2008 March 2008 TX0006661186
06/19/2009 March 2008 TX0006679504
08/14/2008 April 2008 TX0006661185
08/14/2008 May 2008 TX0006662613
10/10/2008 June 2008 TX0006660552
10/10/2008 July 2008 TX0006685302
12/21/2008 August 2008 TX0006663000
12/17/2008 September 2008 TX0006679502
06/08/2009 November 2008 TX0006681694
02/11/2009 October 2008 TX0006631856
03/17/2009 December 2008 TX0006679451
04/22/2009 January 2009 TX0006631561
06/19/2009 February 2009 TX0006679510
07/27/2009 April 2009 TX0006681728
11/24/2009 May 2009 TX0006700124
09/15/2009 June 2009 TX0006684015
11/24/2009 July 2009 TX0006700125
11/24/2009 August 2009 TX0006700123
03/03/2010 September 2009 TX0006702292
03/03/2010 October 2009 TX0006702291
03/03/2010 November 2009 TX0006702295
04/05/2010 December 2009 TX0006718356
04/25/2011 September 2010 TX0006788397
04/25/2011 December 2010 TX0006788398
04/26/2010 January 2010 TX0006703956
06/18/2010 February 2010 TX0006704976
06/18/2010 March 2010 TX0006704975
09/01/2010 April 2010 TX0006705120
03/03/2011 June 2010 TX0006772868
01/03/2011 July 2010 TX0006771498
02/02/2011 August 2010 TX0006782644
03/03/2011 October 2010 TX0006772870
03/03/2011 November 2010 TX0006772869
01/06/2012 June 2011 TX0006788818
01/06/2012 July 2011 TX0006788816
01/06/2012 August 2011 TX0006788817
02/06/2012 September 2011 TX0006787902
03/12/2012 November 2011 TX0006790412
04/02/2012 December 2011 TX0006789326
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 5 of 8

07/25/2011 January 2011 TX0006783648


07/25/2011 February 2011 TX0006783649
09/09/2011 March 2011 TX0006789305
09/09/2011 May 2011 TX0006789304
02/17/2012 October 2011 TX0006787896
04/30/2012 January 2012 TX0006789370
04/30/2012 February 2012 TX0006573240
05/23/2012 March 2012 TX0006790186
07/19/2012 April 2012 TX0006573233
10/12/2012 May 2012 TX0006573066
10/31/2012 June 2012 TX0006604579
10/31/2012 July 2012 TX0006604582
01/14/2013 August 2012 TX0007724919
01/23/2013 September 2012 TX0007727672
03/21/2013 December 2012 TX0007799098
04/04/2013 October 2012 TX0008064892
04/04/2013 November 2012 TX0008064900
04/15/2013 January 2013 TX0007911998
08/02/2013 February 2013 TX0007899017
09/11/2013 March 2013 TX0007907688
11/20/2013 May 2013 TX0007898279
03/14/2014 August 2013 TX0008090398
03/14/2014 September 2013 TX0008090425
03/14/2014 October 2013 TX0008090437
09/04/2014 January 2014 TX0008156292
11/05/2014 February 2014 TX0008084839
01/12/2015 March 2014 TX0008153311
01/12/2015 May 2014 TX0008153381
01/12/2015 April 2014 TX0008155891
01/15/2015 July 2014 TX0008047965
01/15/2015 June 2014 TX0008054114
06/08/2015 August 2014 TX0008178860
06/08/2015 September 2014 TX0008178865
06/08/2015 October 2014 TX0008178885
06/17/2015 November 2014 TX0008178911
06/17/2015 December 2014 TX0008178917
08/14/2015 January 2015 TX0008200774
10/15/2015 March 2015 TX0008227432
10/15/2015 February 2015 TX0008227439
10/26/2015 May 2015 TX0008227993
10/26/2015 June 2015 TX0008228000
12/16/2015 July 2015 TX0008240821
12/28/2015 August 2015 TX0008249086
01/04/2016 September 2015 TX0008246152
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 6 of 8

01/19/2016 October 2015 TX0008215619


06/02/2016 December 2015 TX0008337843
06/02/2016 November 2015 TX0008337889
09/27/2016 April 2016 TX0008309272
09/27/2016 June 2016 TX0008309342
09/27/2016 March 2016 TX0008309347
02/03/2017 February 2016 TX0008353847
02/03/2017 July 2016 TX0008353765
02/03/2017 August 2016 TX0008353821
02/03/2017 September 2016 TX0008354427
02/06/2017 January 2016 TX0008354310
11/13/2017 July 2017 TX0008475899
11/13/2017 January 2017 TX0008475922
11/13/2017 February 2017 TX0008476048
11/13/2017 May 2017 TX0008475908
11/13/2017 June 2017 TX0008476038
11/13/2017 March 2017 TX0008475912
11/13/2017 April 2017 TX0008476043
11/24/2017 August 2017 TX0008475752
03/29/2018 January 2018 TX0008532854
04/27/2018 February 2018 TX0008532939
05/15/2018 March 2018 TX0008548235
06/19/2018 April 2018 TX0008570675
07/17/2018 May 2018 TX0008580042
08/20/2018 June 2018 TX0008588964
09/12/2018 August 2018 TX0008599029
09/12/2018 July 2018 TX0008598977
10/09/2018 September 2018 TX0008667273
10/31/2018 October 2018 TX0008667563
12/02/2018 November 2018 TX0008670834
01/03/2019 December 2018 TX0008671449
01/31/2019 January 2019 TX0008696397
02/28/2019 February 2019 TX0008721013
04/01/2019 March 2019 TX0008797434
04/30/2019 April 2019 TX0008794603
06/03/2019 May 2019 TX0008793383
07/01/2019 June 2019 TX0008798042
08/06/2019 July 2019 TX0008804861
09/02/2019 August 2019 TX0008806552
10/02/2019 September 2019 TX0008824859
10/31/2019 October 2019 TX0008822109
12/02/2019 November 2019 TX0008827202
12/31/2019 December 2019 TX0008829802
02/03/2020 January 2020 TX0008850162
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 7 of 8

03/02/2020 February 2020 TX0008867137


03/31/2020 March 2020 TX0008864760
04/30/2020 April 2020 TX0008874257
06/09/2020 May 2020 TX0008884711
06/30/2020 June 2020 TX0008885598
08/03/2020 July 2020 TX0008890519
08/31/2020 August 2020 TX0008898910
10/01/2020 September 2020 TX0008909536
11/02/2020 October 2020 TX0008918119
11/30/2020 November 2020 TX0008923130
01/04/2021 December 2020 TX0008931222
02/02/2021 January 2021 TX0008940875
03/02/2021 February 2021 TX0008952604
04/01/2021 March 2021 TX0008958993
05/03/2021 April 2021 TX0008970034
06/08/2021 May 2021 TX0009145389
06/30/2021 June 2021 TX0008994117
08/05/2021 July 2021 TX0009011702
08/31/2021 August 2021 TX0009021168
09/30/2021 September 2021 TX0009060159
11/01/2021 October 2021 TX0009079041
11/30/2021 November 2021 TX0009101702
01/06/2022 December 2021 TX0009120550
02/01/2022 January 2022 TX0009130692
03/15/2022 February 2022 TX0009140874
04/01/2022 March 2022 TX0009144897
05/02/2022 April 2022 TX0009153167
06/02/2022 May 2022 TX0009162736
08/01/2022 July 2022 TX0009179290
09/08/2022 August 2022 TX0009191322
10/04/2022 September 2022 TX0009201142
11/03/2022 June 2022 TX0009190562
11/03/2022 October 2022 TX0009216785
12/01/2022 November 2022 TX0009238737
01/06/2023 December 2022 TX0009259504
02/02/2023 January 2023 TX0009265916
03/06/2023 February 2023 TX0009273292
04/04/2023 March 2023 TX0009279497
05/09/2023 April 2023 TX0009287161
06/09/2023 May 2023 TX0009293145
07/11/2023 June 2023 TX0009302351
08/01/2023 July 2023 TX0009304183
09/14/2023 August 2023 TX0009320061
10/03/2023 September 2023 TX0009327673
Case 1:24-cv-03285 Document 1-3 Filed 04/30/24 Page 8 of 8

11/09/2023 October 2023 TX0009334276


12/14/2023 November 2023 TX0009357080
01/04/2024 December 2023 TX0009361592
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 1 of 9

EXHIBIT D
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 2 of 9

SUN SENTINEL
Registration Date Issue Registered (Month/Year) Registration Number
03/08/1993 December 1992 TX0003527410
03/08/1993 January 1993 TX0003527405
03/09/1993 November 1992 TX0003527406
04/07/1993 February 1993 TX0003547083
05/26/1993 March 1993 TX0003562140
07/06/1993 April 1993 TX0003629840
08/10/1993 May 1993 TX0003629783
08/11/1993 June 1993 TX0003629784
10/05/1993 July 1993 TX0003694360
10/14/1993 August 1993 TX0003694355
11/17/1993 September 1993 TX0003694320
12/27/1993 October 1993 TX0003754666
01/18/1994 November 1993 TX0003703610
03/17/1994 December 1993 TX0003754648
03/22/1994 January 1994 TX0003754658
05/12/1994 March 1994 TX0003774459
06/15/1994 April 1994 TX0003915916
07/08/1994 May 1994 TX0003909687
08/15/1994 June 1994 TX0003915971
09/13/1994 July 1994 TX0003915936
10/03/1994 August 1994 TX0003915978
10/31/1994 September 1994 TX0003941163
11/30/1994 October 1994 TX0003947024
02/02/1995 November 1994 TX0003991886
02/13/1995 December 1994 TX0004004782
03/13/1995 January 1995 TX0004016605
04/03/1995 February 1995 TX0004016597
05/01/1995 March 1995 TX0004101469
06/26/1995 April 1995 TX0004083434
07/17/1995 May 1995 TX0004083405
08/07/1995 June 1995 TX0004101876
09/13/1995 July 1995 TX0004101851
10/05/1995 August 1995 TX0004150570
11/08/1995 September 1995 TX0004130439
12/05/1995 October 1995 TX0004165921
01/16/1996 November 1995 TX0004181284
02/12/1996 December 1995 TX0004181127
03/06/1996 January 1996 TX0004161562
04/01/1996 February 1996 TX0004194943
04/26/1996 March 1996 TX0004204343
05/23/1996 April 1996 TX0004234064
07/05/1996 May 1996 TX0004307862
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 3 of 9

08/15/1996 June 1996 TX0004306164


08/30/1996 July 1996 TX0004333205
09/13/1996 August 1996 TX0004336849
10/15/1996 September 1996 TX0004339969
11/13/1996 October 1996 TX0004362686
12/10/1996 November 1996 TX0004390824
01/28/1997 December 1996 TX0004419856
02/26/1997 January 1997 TX0004420707
03/18/1997 February 1997 TX0004439672
04/21/1997 March 1997 TX0004468842
08/28/1997 March 1997 TX0004538068
09/05/1997 April 1997 TX0004538121
09/05/1997 May 1997 TX0004538104
09/05/1997 June 1997 TX0004538105
09/18/1997 July 1997 TX0004548661
11/24/1997 August 1997 TX0004572895
12/08/1997 September 1997 TX0004580580
12/12/1997 October 1997 TX0004616384
02/04/1998 November 1997 TX0004612225
03/04/1998 December 1997 TX0004625245
03/16/1998 January 1998 TX0004625428
04/03/1998 February 1998 TX0004668514
05/07/1998 March 1998 TX0004682250
05/28/1998 April 1998 TX0004706119
08/27/1998 May 1998 TX0004740456
08/27/1998 June 1998 TX0004740485
10/09/1998 July 1998 TX0004787264
11/06/1998 August 1998 TX0004784019
11/20/1998 September 1998 TX0004798433
02/12/1999 November 1998 TX0004842086
03/03/1999 December 1998 TX0004858666
03/18/1999 January 1999 TX0004858624
04/22/1999 February 1999 TX0004920393
05/18/1999 March 1999 TX0004903308
06/21/1999 April 1999 TX0004920323
06/28/1999 October 1998 TX0004935343
06/28/1999 May 1999 TX0004920181
09/07/1999 June 1999 TX0004979355
09/07/1999 July 1999 TX0004979370
11/15/1999 September 1999 TX0005028455
01/11/2000 November 1999 TX0005023369
02/04/2000 December 1999 TX0005041551
03/01/2000 January 2000 TX0005052082
04/03/2000 February 2000 TX0005651802
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 4 of 9

05/03/2000 March 2000 TX0005108521


06/05/2000 April 2000 TX0005108508
07/07/2000 May 2000 TX0005132911
08/02/2000 June 2000 TX0005146126
09/05/2000 July 2000 TX0005164180
10/10/2000 August 2000 TX0005173589
11/20/2000 September 2000 TX0005193580
12/11/2000 October 2000 TX0005214063
03/01/2001 November 2000 TX0005254007
03/01/2001 December 2000 TX0005253996
03/19/2001 January 2001 TX0005286904
05/29/2001 March 2001 TX0005321485
06/07/2001 February 2001 TX0005321461
08/08/2001 May 2001 TX0005355326
08/09/2001 April 2001 TX0005355323
08/13/2001 June 2001 TX0005355328
05/01/2002 November 2001 TX0005554608
05/01/2002 December 2001 TX0005554602
05/01/2002 January 2002 TX0005554586
05/01/2002 February 2002 TX0005554584
05/16/2002 July 2001 TX0005647147
05/16/2002 August 2001 TX0005647144
05/16/2002 September 2001 TX0005647148
05/28/2002 October 2001 TX0005647145
06/27/2002 April 2002 TX0005582056
07/01/2002 March 2002 TX0005647146
09/11/2002 May 2002 TX0005682004
09/11/2002 June 2002 TX0005647231
09/18/2002 July 2002 TX0005600371
11/07/2002 August 2002 TX0005807226
01/10/2003 August 2002 TX0005651842
01/10/2003 September 2002 TX0005654159
01/10/2003 October 2002 TX0005651916
03/19/2003 January 2003 TX0005702676
04/09/2003 December 2002 TX0005964842
09/19/2003 March 2003 TX0005809526
09/19/2003 May 2003 TX0005809531
09/23/2003 April 2003 TX0005809490
09/23/2003 June 2003 TX0005809492
09/23/2003 July 2003 TX0005809489
12/05/2003 August 2003 TX0005870376
12/05/2003 September 2003 TX0005897571
02/13/2004 November 2003 TX0005892675
02/13/2004 October 2003 TX0006511564
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 5 of 9

04/05/2004 December 2003 TX0005921881


04/05/2004 January 2004 TX0005921919
04/05/2004 February 2004 TX0005921887
06/08/2004 March 2004 TX0005986951
08/04/2004 April 2004 TX0005999964
08/04/2004 May 2004 TX0005999973
08/12/2004 September 2004 TX0006079516
11/12/2004 June 2004 TX0006079512
11/12/2004 July 2004 TX0006079513
11/12/2004 August 2004 TX0006079514
02/10/2005 November 2004 TX0006110288
02/10/2005 December 2004 TX0006110270
05/09/2005 January 2005 TX0006172151
05/09/2005 October 2004 TX0006197989
09/13/2005 June 2005 TX0006511565
09/13/2005 April 2005 TX0006222412
01/22/2007 November 2006 TX0006505116
02/15/2007 September 2006 TX0006519620
03/16/2007 August 2006 TX0006519619
04/04/2007 December 2006 TX0006613641
05/29/2007 March 2007 TX0006630112
07/27/2007 May 2007 TX0006614499
08/13/2007 April 2007 TX0006644536
08/13/2007 June 2007 TX0006644535
11/15/2007 July 2007 TX0006630309
11/15/2007 August 2007 TX0006630310
01/10/2008 September 2007 TX0006645696
01/10/2008 October 2007 TX0006645697
03/03/2008 November 2007 TX0006647463
03/03/2008 December 2007 TX0006647462
05/15/2008 January 2008 TX0006647199
05/15/2008 February 2008 TX0006647198
05/15/2008 March 2008 TX0006647200
07/25/2008 April 2008 TX0006662405
07/25/2008 May 2008 TX0006662406
10/30/2008 June 2008 TX0006660469
10/30/2008 July 2008 TX0006664688
10/30/2008 August 2008 TX0006664656
11/19/2008 October 2008 TX0006664827
02/02/2009 October 2008 TX0006664968
02/02/2009 November 2008 TX0006664951
03/11/2009 December 2008 TX0006631660
05/12/2009 February 2009 TX0006679567
06/11/2009 March 2009 TX0006681615
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 6 of 9

06/11/2009 April 2009 TX0006679401


08/20/2009 May 2009 TX0006685344
08/31/2009 June 2009 TX0006687600
09/15/2009 July 2009 TX0006685714
02/02/2010 November 2009 TX0006701507
02/04/2010 October 2009 TX0006701520
04/19/2010 February 2010 TX0006704148
04/22/2010 March 2010 TX0006704961
04/23/2010 January 2009 TX0006772181
04/23/2010 February 2009 TX0006772182
04/23/2010 March 2009 TX0006772183
04/23/2010 April 2009 TX0006772184
04/23/2010 May 2009 TX0006772185
04/23/2010 June 2009 TX0006772186
04/23/2010 July 2009 TX0006772187
04/23/2010 August 2009 TX0006772188
04/23/2010 September 2009 TX0006772189
04/23/2010 October 2009 TX0006782649
04/23/2010 November 2009 TX0006772190
04/23/2010 December 2009 TX0006772191
06/06/2010 April 2010 TX0006704869
07/30/2010 May 2010 TX0006705066
11/01/2010 June 2010 TX0006718521
11/12/2010 July 2010 TX0006718508
02/24/2011 August 2010 TX0006772965
03/21/2011 October 2010 TX0006772782
05/10/2011 November 2010 TX0006776301
05/30/2011 December 2011 TX0006790165
05/31/2011 January 2011 TX0006778363
07/11/2011 February 2011 TX0006778827
08/01/2011 March 2011 TX0006778888
08/01/2011 May 2011 TX0006778889
08/09/2011 April 2011 TX0006778994
08/30/2011 December 2010 TX0006787783
09/29/2011 June 2010 TX0006787602
09/30/2011 July 2011 TX0006787567
01/31/2012 October 2011 TX0006787892
03/12/2012 November 2011 TX0006789383
05/30/2012 January 2012 TX0006790166
07/30/2012 April 2012 TX0006612371
09/07/2012 March 2012 TX000660117
10/02/2012 May 2012 TX0006604556
11/05/2012 June 2012 TX0006601101
11/05/2012 July 2012 TX0006604576
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 7 of 9

01/03/2013 August 2012 TX0007875448


01/23/2013 October 2012 TX0007727662
02/05/2013 September 2012 TX0007802880
03/04/2013 November 2012 TX0007750207
05/15/2013 January 2013 TX0007884944
05/15/2013 March 2013 TX0007884955
07/15/2013 April 2013 TX0007881053
10/21/2013 June 2013 TX0007876524
10/21/2013 May 2013 TX0007876624
02/03/2014 August 2013 TX0008005459
02/03/2014 September 2013 TX0008005475
02/03/2014 October 2013 TX0008005618
06/05/2014 November 2013 TX0007945367
06/05/2014 December 2013 TX0007945895
07/28/2014 February 2014 TX0007982426
07/28/2014 January 2014 TX0008000966
05/24/2016 March 2015 TX0008264112
05/24/2016 December 2015 TX0008264119
05/24/2016 February 2015 TX0008265842
05/24/2016 April 2015 TX0008271486
05/24/2016 January 2015 TX0008271488
05/24/2016 January 2016 TX0008271490
05/25/2016 February 2016 TX0008271480
06/20/2016 May 2015 TX0008278398
12/02/2016 June 2015 TX0008385434
12/02/2016 September 2015 TX0008385467
12/02/2016 April 2016 TX0008385478
12/02/2016 July 2015 TX0008385498
12/02/2016 May 2016 TX0008385507
12/02/2016 June 2016 TX0008385546
12/02/2016 August 2015 TX0008385550
12/16/2016 July 2016 TX0008301742
12/16/2016 October 2015 TX0008301901
01/06/2017 October 2016 TX0008379999
01/06/2017 September 2016 TX0008383144
01/06/2017 August 2016 TX0008383830
02/01/2017 November 2016 TX0008354290
03/21/2017 December 2016 TX0008359824
08/17/2017 January 2017 TX0008457670
08/17/2017 February 2017 TX0008457686
09/01/2017 March 2017 TX0008433789
09/15/2017 April 2017 TX0008447258
09/27/2017 May 2017 TX0008427230
10/12/2017 June 2017 TX0008434077
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 8 of 9

11/06/2017 July 2017 TX0008473066


11/06/2017 August 2017 TX0008473156
12/29/2017 September 2017 TX0008491034
02/20/2018 November 2017 TX0008513462
02/20/2018 October 2017 TX0008513487
03/29/2018 December 2017 TX0008637277
03/30/2018 January 2018 TX0008533943
09/13/2018 February 2018 TX0008603829
04/28/2020 March 2020 TX0008871660
04/28/2020 December 2019 TX0008873051
04/28/2020 January 2020 TX0008873102
04/28/2020 February 2020 TX0008873206
04/28/2020 November 2019 TX0008873342
04/30/2020 October 2019 TX0008876242
04/30/2020 April 2020 TX0008879497
06/01/2020 May 2020 TX0008882606
06/17/2020 May 2018 TX0008884204
06/19/2020 June 2018 TX0008883902
06/22/2020 September 2018 TX0008885014
06/23/2020 June 2019 TX0008885625
06/30/2020 June 2020 TX0008887923
08/15/2020 July 2020 TX0008894781
08/15/2020 July 2019 TX0008894820
09/01/2020 August 2020 TX0008898650
09/02/2020 August 2019 TX0008898630
09/02/2020 January 2019 TX0008900260
09/02/2020 September 2019 TX0008900414
10/02/2020 September 2020 TX0008909216
10/02/2020 April 2019 TX0008909457
10/02/2020 May 2019 TX0008910905
11/08/2020 October 2018 TX0008920913
11/08/2020 November 2018 TX0008920931
11/08/2020 December 2018 TX0008921250
12/05/2020 November 2020 TX0008924237
01/07/2021 December 2020 TX0008935371
05/08/2021 March 2021 TX0008975650
06/18/2021 May 2021 TX0008991711
01/14/2022 August 2021 TX0009095383
01/14/2022 September 2021 TX0009122820
01/16/2022 October 2021 TX0009123180
02/19/2022 November 2021 TX0009130316
03/04/2022 January 2022 TX0009135719
03/04/2022 December 2021 TX0009139817
05/13/2022 February 2022 TX0009156710
Case 1:24-cv-03285 Document 1-4 Filed 04/30/24 Page 9 of 9

05/13/2022 March 2019 TX0009156750


05/13/2022 February 2019 TX0009156763
06/03/2022 March 2022 TX0009162712
06/26/2022 April 2022 TX0009170454
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 1 of 6

EXHIBIT E
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 2 of 6

THE MERCURY NEWS


Registration Date Issue Registered (Month/Year) Registration Number
07/06/2007 January 2007 TX0006608020
06/22/2007 February 2007 TX0006587926
07/24/2007 March 2007 TX0006630313
09/17/2007 April 2007 TX0006630145
09/17/2007 May 2007 TX0006630117
10/19/2007 June 2007 TX0006630399
01/14/2008 July 2007 TX0006647506
01/14/2008 August 2007 TX0006647507
03/06/2008 September 2007 TX0006647449
04/28/2008 October 2007 TX0006647157
06/05/2008 November 2007 TX0006647196
06/05/2008 December 2007 TX0006647197
08/28/2008 April 2008 TX0006662657
08/28/2008 May 2008 TX0006662655
11/20/2008 June 2008 TX0006660490
11/20/2009 July 2008 TX0006679505
03/13/2008 August 2008 TX0006660491
03/13/2009 September 2008 TX0006679506
03/13/2009 October 2008 TX0006679507
11/18/2009 November 2008 TX0006700136
09/10/2009 December 2008 TX0006683996
09/10/2009 January 2009 TX0006683997
09/10/2009 February 2009 TX0006683995
11/18/2009 March 2009 TX0006700134
11/18/2009 April 2009 TX0006700135
02/09/2010 May 2009 TX0006701508
02/09/2010 June 2009 TX0006701509
02/09/2010 July 2009 TX0006701509
06/23/2010 August 2009 TX0006704959
06/23/2010 September 2009 TX0006704963
06/23/2010 October 2009 TX0006704962
06/23/2010 November 2009 TX0006704966
06/23/2010 December 2009 TX0006704967
06/23/2010 January 2010 TX0006704958
11/17/2010 February 2010 TX0006771662
11/17/2010 March 2010 TX0006771663
01/25/2011 April 2010 TX0006772259
01/25/2011 May 2010 TX0006772260
01/28/2011 June 2010 TX0006771521
01/28/2011 July 2010 TX0006771520
02/16/2011 August 2010 TX0006776118
02/16/2011 September 2010 TX0006776117
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 3 of 6

04/13/2011 October 2010 TX0006776365


04/13/2011 November 2010 TX0006776363
05/26/2011 December 2010 TX0006776146
05/26/2011 January 2011 TX0006776147
07/25/2011 February 2011 TX0006778898
07/25/2011 March 2011 TX0006778897
09/30/2011 May 2011 TX0006789302
12/30/2011 June 2011 TX0006788724
12/30/2011 July 2011 TX0006788752
02/15/2012 August 2011 TX0006788019
02/15/2012 September 2011 TX0006788016
04/24/2012 October 2011 TX0006789758
04/24/2012 November 2011 TX0006789753
05/14/2012 December 2011 TX0006789780
05/14/2012 January 2012 TX0006789785
11/16/2012 April 2012 TX0006573053
11/16/2012 May 2012 TX0006573042
10/22/2012 March 2012 TX0008228891
10/22/2012 February 2012 TX0007787046
01/25/2013 July 2012 TX0007903526
01/25/2013 June 2012 TX0007903518
03/07/2013 September 2012 TX0007911740
03/07/2013 August 2012 TX0007911751
04/01/2013 October 2012 TX0007713127
04/01/2013 November 2012 TX0007713125
06/04/2013 January 2013 TX0007767876
06/04/2013 December 2012 TX0007767893
09/12/2013 March 2013 TX0008057052
09/12/2013 February 2013 TX0008057036
10/25/2013 May 2013 TX0007901542
10/25/2013 April 2013 TX0007901503
01/13/2014 June 2013 TX0008083258
04/09/2014 August 2013 TX0007949744
04/09/2014 September 2013 TX0007955970
06/20/2014 October 2013 TX0007927968
06/20/2014 November 2013 TX0007927979
09/18/2014 January 2014 TX0007958533
09/18/2014 December 2013 TX0007958509
01/20/2015 March 2014 TX0008053458
01/20/2015 February 2014 TX0008048403
03/12/2015 April 2014 TX0008151909
03/12/2015 June 2014 TX0008151967
03/12/2015 May 2014 TX0008151896
03/12/2015 July 2014 TX0008151999
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 4 of 6

05/08/2015 August 2014 TX0008163108


05/08/2015 September 2014 TX0008163088
06/24/2015 July 2013 TX0008083298
07/16/2015 November 2014 TX0008183593
07/16/2015 December 2014 TX0008183600
09/23/2015 February 2015 TX0008148518
09/23/2015 January 2015 TX0008148433
10/29/2015 April 2015 TX0008227949
10/29/2015 March 2015 TX0008227937
10/29/2015 October 2014 TX0008227976
10/29/2015 May 2015 TX0008227970
01/07/2016 June 2015 TX0008569351
01/07/2016 July 2015 TX0008255592
01/07/2016 May 2015 TX0008255797
01/07/2016 August 2015 TX0008255584
03/24/2016 September 2015 TX0008265270
03/24/2016 October 2015 TX0008265273
04/13/2016 November 2015 TX0008266332
04/13/2016 December 2015 TX0008266338
08/09/2016 February 2016 TX0008299105
08/09/2016 January 2016 TX0008299075
12/12/2016 April 2016 TX0008284092
12/12/2016 May 2016 TX0008284282
12/12/2016 March 2016 TX0008284105
12/12/2016 June 2016 TX0008284342
04/18/2017 August 2016 TX0008382239
04/18/2017 July 2016 TX0008382255
08/31/2017 January 2017 TX0008447901
08/31/2017 December 2016 TX0008447795
08/31/2017 October 2016 TX0008447818
08/31/2017 September 2016 TX0008447854
08/31/2017 February 2017 TX0008447765
08/31/2017 April 2017 TX0008447870
08/31/2017 March 2017 TX0008447828
08/31/2017 November 2016 TX0008447784
12/13/2017 July 2017 TX0008491101
12/13/2017 August 2017 TX0008491082
12/13/2017 May 2017 TX0008491106
12/13/2017 June 2017 TX0008491124
12/13/2017 October 2017 TX0008731190
12/13/2017 September 2017 TX0008491509
04/10/2018 March 2018 TX0008538126
04/23/2018 January 2018 TX0008645154
04/30/2018 February 2018 TX0008645158
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 5 of 6

05/03/2018 April 2018 TX0008538133


06/05/2018 May 2018 TX0008550998
07/05/2018 June 2018 TX0008579348
08/07/2018 July 2018 TX0008581880
09/05/2018 August 2018 TX0008594922
10/12/2018 September 2018 TX0008667374
11/16/2018 October 2018 TX0008667964
12/10/2018 November 2018 TX0008668242
02/19/2019 January 2019 TX0008700772
03/19/2019 February 2019 TX0008742510
04/04/2019 December 2018 TX0008699814
05/14/2019 March 2019 TX0008794893
05/31/2019 April 2019 TX0008793465
07/26/2019 June 2019 TX0008800741
08/26/2019 July 2019 TX0008803687
09/17/2019 August 2019 TX0008819332
10/29/2019 September 2019 TX0008823888
11/18/2019 May 2019 TX0008803605
12/02/2019 October 2019 TX0008825729
12/31/2019 November 2019 TX0008830464
01/17/2020 December 2019 TX0008840280
02/25/2020 January 2020 TX0008860525
03/18/2020 February 2020 TX0008862064
04/16/2020 March 2020 TX0008865328
05/13/2020 April 2020 TX0008876170
06/24/2020 May 2020 TX0008885763
07/22/2020 June 2020 TX0008888013
09/04/2020 July 2020 TX0008901405
10/12/2020 August 2020 TX0008913989
12/04/2020 September 2020 TX0008923480
12/15/2020 October 2020 TX0008926307
01/04/2021 November 2020 TX0008935362
01/15/2021 December 2020 TX0008935292
02/24/2021 January 2021 TX0008949859
03/26/2021 February 2021 TX0008957988
05/19/2021 March 2021 TX0009004214
05/28/2021 April 2021 TX0008980808
06/28/2021 May 2021 TX0008994111
09/07/2021 June 2021 TX0009011492
10/06/2021 July 2021 TX0009063815
11/03/2021 September 2021 TX0009080226
11/03/2021 August 2021 TX0009078793
12/01/2021 October 2021 TX0009101109
02/07/2022 December 2021 TX0009128945
Case 1:24-cv-03285 Document 1-5 Filed 04/30/24 Page 6 of 6

03/16/2022 January 2022 TX0009140838


04/22/2022 February 2022 TX0009148893
04/25/2022 March 2022 TX0009151964
05/23/2022 November 2021 TX0009125285
06/13/2022 April 2022 TX0009170462
07/01/2022 May 2022 TX0009179413
07/25/2022 June 2022 TX0009178724
08/31/2022 July 2022 TX0009189532
09/26/2022 August 2022 TX0009193087
10/31/2022 September 2022 TX0009218483
01/11/2023 November 2022 TX0009262393
02/10/2023 December 2022 TX0009268545
03/10/2023 January 2023 TX0009273884
03/29/2023 February 2023 TX0009280323
03/29/2023 October 2022 TX0009239946
04/12/2023 March 2023 TX0009283049
06/02/2023 April 2023 TX0009292883
06/30/2023 May 2023 TX0009299577
07/21/2023 June 2023 TX0009305049
09/13/2023 July 2023 TX0009320187
09/22/2023 August 2023 TX0009322493
10/13/2023 September 2023 TX0009327922
11/29/2023 October 2023 TX0009339252
12/20/2023 November 2023 TX0009353919
01/05/2024 December 2023 TX0009359752
02/28/2024 January 2024 TX0009381597
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 1 of 6

EXHIBIT F
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 2 of 6

THE DENVER POST


Registration Date Issue Registered (Month/Year) Registration Number
02/26/2007 December 2006 TX0006520751
03/30/2007 January 2007 TX0006550595
04/30/2007 February 2007 TX0006614019
06/14/2007 March 2007 TX0006587016
06/29/2007 April 2007 TX0006587451
10/15/2007 April 2007 TX0006645691
07/20/2007 May 2007 TX0006630312
10/15/2007 June 2007 TX0006645690
10/04/2007 July 2007 TX0006630528
11/08/2007 August 2007 TX0006630542
11/15/2007 September 2007 TX0006630302
01/09/2008 October 2007 TX0006662882
02/01/2008 November 2007 TX0006647563
04/04/2008 December 2007 TX0006648696
04/04/2008 January 2008 TX0006648722
05/05/2008 February 2008 TX0006647368
06/04/2008 March 2008 TX0006648709
06/21/2008 April 2008 TX0006661256
07/24/2008 May 2008 TX0006661187
09/19/2008 June 2008 TX0006665134
10/02/2008 July 2008 TX0006685291
11/03/2008 August 2008 TX0006660461
01/16/2009 October 2008 TX0006664987
01/24/2009 November 2008 TX0006631916
03/10/2009 December 2008 TX0006680109
05/01/2009 January 2009 TX0006631564
05/08/2009 February 2009 TX0006631557
06/16/2009 March 2009 TX0006681701
06/26/2009 April 2009 TX0006685079
07/23/2009 May 2009 TX0006679395
08/25/2009 June 2009 TX0006685238
09/07/2009 July 2009 TX0006685352
10/29/2009 August 2009 TX0006700121
11/13/2009 September 2009 TX0006700176
12/23/2009 October 2009 TX0006700043
01/29/2010 November 2009 TX0006702312
03/16/2010 December 2009 TX0006703966
03/19/2010 January 2010 TX0006702429
05/05/2010 February 2010 TX0006703960
05/27/2010 March 2010 TX0006718501
06/22/2010 April 2010 TX0006705000
08/06/2010 May 2010 TX0006718343
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 3 of 6

11/01/2010 June 2010 TX0006718608


11/17/2010 July 2010 TX0006771445
01/03/2010 August 2010 TX0006771505
02/23/2011 September 2010 TX0006772770
03/18/2011 October 2010 TX0006772918
04/05/2011 November 2010 TX0006772823
04/05/2011 December 2010 TX0006772825
04/11/2011 January 2011 TX0006772828
04/11/2011 February 2011 TX0006772829
07/12/2011 March 2011 TX0006778844
07/12/2011 April 2011 TX0006778840
08/01/2011 May 2011 TX0006778880
08/21/2011 June 2011 TX0006788061
10/18/2011 July 2011 TX0006790059
11/07/2011 August 2011 TX0006787642
12/22/2011 September 2011 TX0006788678
02/07/2012 October 2011 TX0006788030
03/07/2012 November 2011 TX0006790381
03/26/2012 December 2011 TX0006789327
05/14/2012 January 2012 TX0006789319
05/14/2012 February 2012 TX0006789318
06/08/2012 March 2012 TX0006790140
06/25/2012 April 2012 TX0006790196
07/30/2012 May 2012 TX0006612293
08/21/2012 June 2012 TX0006573078
09/12/2012 July 2012 TX0006604665
11/13/2012 September 2012 TX0006604578
10/31/2012 August 2012 TX0007820154
12/18/2012 October 2012 TX0007713092
01/29/2013 November 2012 TX0007695108
02/19/2013 December 2012 TX0007726230
03/05/2013 January 2013 TX0007990145
04/22/2013 February 2013 TX0007902414
05/06/2013 March 2013 TX0007903552
06/10/2013 April 2013 TX0007879025
07/01/2013 May 2013 TX0007811173
07/29/2013 June 2013 TX0007763688
08/26/2013 July 2013 TX0007901250
10/28/2013 August 2013 TX0007876544
12/06/2013 September 2013 TX0007883792
01/03/2014 October 2013 TX0007901377
02/07/2014 November 2013 TX0007878892
02/24/2014 December 2013 TX0007878876
03/18/2014 January 2014 TX0007987763
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 4 of 6

04/14/2014 February 2014 TX0007995715


06/09/2014 March 2014 TX0007945335
06/17/2014 April 2014 TX0007918206
08/04/2014 May 2014 TX0007972129
08/14/2014 June 2014 TX0008082247
09/16/2014 July 2014 TX0007966420
09/26/2014 August 2014 TX0008063651
11/19/2014 September 2014 TX0008078196
12/10/2014 October 2014 TX0007995132
01/26/2015 December 2014 TX0008109722
01/26/2015 November 2014 TX0008109705
04/06/2015 January 2015 TX0008173706
04/13/2015 February 2015 TX0008198376
05/26/2015 March 2015 TX0008156973
06/15/2015 April 2015 TX0008161560
07/08/2015 May 2015 TX0008182599
08/21/2015 June 2015 TX0008204843
10/14/2015 July 2015 TX0008236293
10/19/2015 August 2015 TX0008227413
11/09/2015 September 2015 TX0008238756
12/07/2015 October 2015 TX0008240800
01/11/2016 November 2015 TX0008232327
02/23/2016 December 2015 TX0008261008
02/29/2016 January 2016 TX0008256060
04/05/2016 February 2016 TX0008266334
04/26/2016 March 2016 TX0008264009
06/10/2016 April 2016 TX0008331390
08/01/2016 May 2016 TX0008315868
09/19/2016 July 2016 TX0008347951
10/13/2016 August 2016 TX0008334695
11/21/2016 July 2016 TX0008285238
12/13/2016 September 2016 TX0008284080
01/11/2017 November 2016 TX0008379570
01/11/2017 October 2016 TX0008378209
02/22/2017 December 2016 TX0008371430
03/13/2017 January 2017 TX0008342946
05/09/2017 March 2017 TX0008396825
05/09/2017 February 2017 TX0008440324
06/29/2017 May 2017 TX0008439656
06/29/2017 April 2017 TX0008439635
08/01/2017 June 2017 TX0008467999
08/29/2017 July 2017 TX0008433909
10/31/2017 August 2017 TX0008473234
11/27/2017 October 2017 TX0008498112
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 5 of 6

12/04/2017 September 2017 TX0008498095


04/04/2018 February 2018 TX0008603404
04/04/2018 January 2018 TX0008603412
07/31/2019 July 2019 TX0008803778
07/31/2019 May 2019 TX0008803367
07/31/2019 June 2019 TX0008774328
08/01/2019 January 2019 TX0008803039
08/01/2019 April 2019 TX0008803179
08/01/2019 February 2019 TX0008791540
09/04/2019 August 2019 TX0008806007
11/08/2019 October 2019 TX0008823123
12/11/2019 November 2019 TX0008829393
01/02/2020 December 2019 TX0008832157
01/16/2020 September 2019 TX0008825140
02/04/2020 January 2020 TX0008856322
03/10/2020 February 2020 TX0008862023
04/09/2020 March 2020 TX0008865229
05/04/2020 April 2020 TX0008875823
06/22/2020 May 2020 TX0008885816
11/10/2020 July 2020 TX0008921406
11/10/2020 June 2020 TX0008921373
12/02/2020 October 2020 TX0008923609
12/02/2020 August 2020 TX0008926253
12/21/2020 September 2020 TX0008928810
04/01/2021 March 2021 TX0008959168
06/07/2021 April 2021 TX0008985252
06/08/2021 May 2021 TX0008985626
07/29/2021 June 2021 TX0009008817
01/19/2022 November 2021 TX0009123484
02/09/2022 January 2022 TX0009132046
03/09/2022 February 2022 TX0009138691
04/20/2022 March 2022 TX0009150826
05/09/2022 April 2022 TX0009153792
06/23/2022 May 2022 TX0009170742
06/24/2022 December 2021 TX0009135943
06/28/2022 November 2021 TX0009137053
07/26/2022 June 2022 TX0009178776
10/25/2022 August 2022 TX0009210100
01/19/2023 October 2022 TX0009263610
01/19/2023 November 2022 TX0009263406
01/19/2023 December 2022 TX0009263187
02/28/2023 January 2023 TX0009270547
09/27/2023 March 2023 TX0009322202
09/27/2023 February 2023 TX0009322221
Case 1:24-cv-03285 Document 1-6 Filed 04/30/24 Page 6 of 6

09/28/2023 August 2023 TX0009326435


10/11/2023 September 2023 TX0009327541
10/17/2023 April 2023 TX0009330791
11/20/2023 June 2023 TX0009336722
11/21/2023 May 2023 TX0009332655
11/21/2023 July 2023 TX0009336696
11/21/2023 October 2023 TX0009336662
01/09/2024 December 2023 TX0009359717
02/20/2024 January 2024 TX0009377672
Case 1:24-cv-03285 Document 1-7 Filed 04/30/24 Page 1 of 4

EXHIBIT G
Case 1:24-cv-03285 Document 1-7 Filed 04/30/24 Page 2 of 4

ORANGE COUNTY REGISTER


Registration Date Issue Registered (Month/Year) Registration Number
05/05/2006 January 2006 TX0006349970
05/05/2006 February 2006 TX0006349946
06/30/2006 March 2006 TX0006422049
06/30/2006 April 2006 TX0006422055
10/23/2006 May 2006 TX0006481187
10/23/2006 June 2006 TX0006481186
10/23/2006 July 2006 TX0006436516
11/07/2006 August 2006 TX0006459517
12/19/2006 October 2006 TX0006481158
12/29/2006 September 2006 TX0006505019
01/22/2007 November 2006 TX0006505046
03/05/2007 December 2006 TX0006587419
03/14/2007 January 2007 TX0006522983
04/27/2007 February 2007 TX0006613949
05/01/2007 November 2006 TX0006575585
06/07/2007 March 2007 TX0006587826
07/11/2007 April 2007 TX0006661055
08/10/2007 May 2007 TX0006627910
09/10/2007 June 2007 TX0006627283
09/24/2007 July 2007 TX0006629790
10/01/2007 August 2007 TX0006647218
10/26/2007 September 2007 TX0006630546
01/18/2008 October 2007 TX0006647220
01/28/2008 November 2007 TX0006647221
02/22/2008 December 2007 TX0006647219
05/14/2008 February 2008 TX0006661056
05/30/2008 January 2008 TX0006648879
08/06/2008 March 2008 TX0006661057
08/06/2008 May 2008 TX0006661058
08/08/2008 April 2008 TX0006662816
09/03/2008 June 2008 TX0006660123
09/29/2008 July 2008 TX0006660122
10/24/2008 August 2008 TX0006660124
11/11/2008 September 2008 TX0006664786
01/15/2009 October 2008 TX0006664751
03/27/2009 November 2008 TX0006664952
04/06/2009 January 2009 TX0006631891
05/01/2009 February 2009 TX0006631813
05/18/2009 December 2008 TX0006679364
05/18/2009 March 2009 TX0006631498
07/07/2009 April 2009 TX0006679703
10/09/2009 June 2009 TX0006685208
Case 1:24-cv-03285 Document 1-7 Filed 04/30/24 Page 3 of 4

10/23/2009 July 2009 TX0006700141


11/23/2009 August 2009 TX0006700140
11/27/2009 September 2009 TX0006700142
01/11/2010 May 2009 TX0006771126
01/11/2010 October 2009 TX0006702391
02/01/2010 November 2009 TX0006701499
04/29/2010 December 2009 TX0006704170
07/01/2010 February 2010 TX0006704940
09/03/2010 April 2010 TX0006705125
09/10/2010 March 2010 TX0006705109
09/16/2010 May 2010 TX0006705134
09/16/2010 June 2010 TX0006705136
01/20/2011 August 2010 TX0006771119
02/04/2011 September 2010 TX0006771564
02/04/2011 October 2010 TX0006771565
02/25/2011 November 2010 TX0006772947
05/13/2011 December 2010 TX0006773283
05/13/2011 January 2011 TX0006773282
05/16/2011 February 2011 TX0006773284
07/15/2011 March 2011 TX0006778852
07/15/2011 May 2011 TX0006778850
08/01/2011 April 2011 TX0006778851
09/23/2011 June 2011 TX0006787623
10/07/2011 July 2011 TX0006783623
10/28/2011 August 2011 TX0006787556
12/13/2011 September 2011 TX0006787799
02/27/2012 October 2011 TX0006604672
02/27/2012 November 2011 TX0006604671
04/02/2012 December 2011 TX0006604670
04/09/2012 January 2012 TX0006790399
07/13/2012 February 2012 TX0006604625
07/13/2012 April 2012 TX0006573244
08/20/2012 June 2012 TX0006573044
08/24/2012 March 2012 TX0006573039
10/03/2012 July 2012 TX0006604635
11/30/2012 August 2012 TX0007800018
01/25/2013 October 2012 TX0007800037
02/01/2013 November 2012 TX0007875462
03/08/2013 December 2012 TX0007807509
06/12/2013 January 2013 TX0007883783
06/17/2013 April 2013 TX0007759498
07/10/2013 February 2013 TX0007898525
09/09/2013 March 2013 TX0007905055
09/11/2013 May 2013 TX0007905027
Case 1:24-cv-03285 Document 1-7 Filed 04/30/24 Page 4 of 4

10/25/2013 June 2013 TX0007901956


12/06/2013 July 2013 TX0007886509
12/16/2013 August 2013 TX0007886482
12/27/2013 September 2013 TX0007903584
01/10/2014 October 2013 TX0007903593
06/02/2014 January 2014 TX0008005093
06/02/2014 February 2014 TX0008005124
08/04/2014 March 2014 TX0007918181
08/21/2014 April 2014 TX0008010987
09/17/2014 May 2014 TX0007966214
12/01/2014 July 2014 TX0008108356
12/01/2014 June 2014 TX0008108347
01/07/2016 August 2014 TX0008260020
01/08/2016 September 2014 TX0008260186
01/27/2016 March 2015 TX0008257342
01/27/2016 November 2014 TX0008257341
01/27/2016 October 2014 TX0008257345
01/27/2016 February 2015 TX0008257336
01/27/2016 January 2015 TX0008257335
01/27/2016 December 2014 TX0008257334
03/09/2016 April 2015 TX0008266350
Case 1:24-cv-03285 Document 1-8 Filed 04/30/24 Page 1 of 5

EXHIBIT H
Case 1:24-cv-03285 Document 1-8 Filed 04/30/24 Page 2 of 5

PIONEER PRESS
Registration Date Issue Registered (Month/Year) Registration Number
08/01/2007 March 2007 TX0006647171
08/01/2007 April 2007 TX0006614500
08/02/2007 May 2007 TX0006614515
08/03/2007 February 2007 TX0006614502
08/13/2007 January 2007 TX0006614522
02/26/2008 September 2007 TX0006647015
02/28/2008 June 2007 TX0006646310
02/28/2008 July 2007 TX0006646311
02/28/2008 August 2007 TX0006646312
04/09/2008 October 2007 TX0006647046
05/13/2008 November 2007 TX0006647019
08/06/2008 February 2008 TX0006665147
08/08/2008 January 2008 TX0006660512
12/04/2008 March 2008 TX0006683830
12/04/2008 April 2008 TX0006665071
12/08/2008 June 2008 TX0006665203
01/02/2009 December 2007 TX0006664981
02/18/2009 July 2008 TX0006631857
02/18/2009 August 2008 TX0006631858
02/18/2009 September 2008 TX0006631859
04/14/2009 October 2008 TX0006631562
04/15/2009 November 2008 TX0006631634
05/11/2009 December 2008 TX0006679685
07/14/2009 January 2009 TX0006683984
07/29/2009 February 2009 TX0006681741
07/30/2009 March 2009 TX0006687595
08/18/2009 April 2009 TX0006685384
08/18/2009 May 2009 TX0006687587
12/07/2009 June 2009 TX0006699979
12/07/2009 July 2009 TX0006699978
01/19/2010 September 2009 TX0006701593
01/19/2010 August 2009 TX0006702389
02/05/2010 October 2009 TX0006701504
02/05/2010 November 2009 TX0006702316
07/21/2010 January 2010 TX0006705011
07/21/2010 February 2010 TX0006705006
08/03/2010 March 2009 TX0006718340
09/08/2010 December 2009 TX0006718433
09/08/2010 April 2009 TX0006718431
02/16/2011 June 2010 TX0006772133
02/16/2011 July 2010 TX0006772132
02/16/2011 May 2009 TX0006772104
Case 1:24-cv-03285 Document 1-8 Filed 04/30/24 Page 3 of 5

03/14/2011 September 2010 TX0006772908


03/14/2011 October 2010 TX0006772909
03/24/2011 May 2011 TX0006787751
08/02/2011 December 2010 TX0006783646
08/02/2011 January 2011 TX0006783637
08/02/2011 February 2011 TX0006783636
08/02/2011 January 2011 TX0006778907
08/24/2011 April 2011 TX0006787750
02/02/2012 June 2011 TX0006789469
02/02/2012 July 2011 TX0006789470
02/02/2012 August 2011 TX0006788703
03/01/2012 September 2011 TX0006788800
03/01/2012 October 2011 TX0006787589
03/28/2012 December 2011 TX0006604552
04/04/2012 November 2011 TX0006790402
05/11/2012 February 2012 TX0006686635
05/23/2012 March 2012 TX0006686634
05/31/2012 January 2012 TX0006686633
08/01/2012 April 2012 TX0006790303
08/10/2012 May 2012 TX0006601097
09/14/2012 June 2012 TX0006789874
01/17/2013 July 2012 TX0007807058
01/18/2013 August 2012 TX0007807478
04/24/2013 September 2012 TX0007742483
04/24/2013 December 2012 TX0008518288
04/24/2013 November 2012 TX0007746820
04/24/2013 October 2012 TX0007742471
10/30/2013 January 2013 TX0007892139
10/30/2013 July 2013 TX0007892874
10/30/2013 May 2013 TX0007879828
10/30/2013 June 2013 TX0007892141
04/30/2014 September 2013 TX0008007422
04/30/2014 August 2013 TX0008007409
04/30/2014 November 2013 TX0007886973
04/30/2014 October 2013 TX0007886921
05/05/2014 December 2013 TX0007949746
05/14/2014 February 2014 TX0007950932
05/14/2014 January 2014 TX0007949741
05/20/2014 March 2014 TX0007914235
09/22/2014 April 2014 TX0007958537
11/13/2014 May 2014 TX0008084800
11/17/2014 June 2014 TX0008029356
02/02/2015 July 2014 TX0008108596
03/02/2015 August 2014 TX0008153078
Case 1:24-cv-03285 Document 1-8 Filed 04/30/24 Page 4 of 5

04/17/2015 September 2014 TX0008064540


05/06/2015 October 2014 TX0008177154
05/18/2015 December 2014 TX0008153165
06/12/2015 November 2014 TX0008179307
06/12/2015 January 2015 TX0008179312
08/17/2015 March 2015 TX0008204888
08/17/2015 February 2015 TX0008204961
09/11/2015 April 2015 TX0008228519
10/26/2015 May 2015 TX0008231529
10/26/2015 June 2015 TX0008234698
12/09/2015 August 2015 TX0008250275
12/09/2015 July 2015 TX0008240720
02/08/2016 September 2015 TX0008330276
02/11/2016 November 2015 TX0008259280
02/11/2016 October 2015 TX0008329721
10/07/2016 June 2016 TX0008299609
10/26/2016 July 2016 TX0008315013
10/26/2016 August 2016 TX0008315019
11/14/2016 September 2016 TX0008569289
01/09/2017 October 2016 TX0008383918
03/15/2017 December 2016 TX0008382095
03/15/2017 January 2017 TX0008359814
05/02/2017 February 2017 TX0008396872
05/11/2017 November 2016 TX0008396874
06/20/2017 March 2017 TX0008483555
06/20/2017 April 2017 TX0008408375
07/07/2017 May 2017 TX0008399096
08/29/2017 June 2017 TX0008433869
01/05/2018 August 2017 TX0008507413
01/31/2018 September 2017 TX0008507401
03/14/2019 January 2019 TX0008756037
07/16/2019 March 2019 TX0008800295
07/23/2019 December 2018 TX0008795942
07/24/2019 February 2019 TX0008788550
07/25/2019 April 2019 TX0008801219
07/29/2019 May 2019 TX0008803906
07/29/2019 June 2019 TX0008804014
09/10/2019 July 2019 TX0008804107
12/11/2019 September 2018 TX0008821207
01/30/2020 September 2019 TX0008841044
02/19/2020 October 2019 TX0008839746
02/26/2020 November 2019 TX0008842680
03/31/2020 December 2019 TX0008863350
03/31/2020 January 2020 TX0008864801
Case 1:24-cv-03285 Document 1-8 Filed 04/30/24 Page 5 of 5

06/16/2020 April 2020 TX0008885002


06/16/2020 March 2020 TX0008885313
06/16/2020 May 2020 TX0008885583
06/16/2020 February 2020 TX0008885009
11/01/2020 June 2020 TX0008916013
11/01/2020 October 2019 TX0008915753
01/21/2021 August 2020 TX0008936378
01/28/2021 October 2020 TX0008942800
02/11/2021 November 2020 TX0008945331
03/14/2021 September 2020 TX0008943134
04/21/2021 July 2020 TX0008965430
04/21/2021 January 2021 TX0008965200
04/23/2021 February 2021 TX0008974853
04/23/2021 March 2021 TX0008969081
07/01/2021 December 2020 TX0008980273
08/04/2021 April 2021 TX0009007010
08/19/2021 July 2021 TX0009014384
08/19/2021 May 2021 TX0009014245
08/19/2021 June 2021 TX0009014132
09/27/2021 August 2019 TX0009010051
09/27/2021 August 2021 TX0009061286
10/21/2021 September 2021 TX0009075320
03/29/2022 October 2021 TX0009145276
03/29/2022 December 2021 TX0009145868
03/29/2022 November 2021 TX0009145310
04/13/2022 January 2022 TX0009136065
04/13/2022 February 2022 TX0009148358
06/08/2022 March 2022 TX0009165885
06/08/2022 April 2022 TX0009166057
12/13/2022 May 2022 TX0009252733
12/13/2022 July 2022 TX0009250569
12/14/2022 September 2022 TX0009250613
04/25/2023 November 2022 TX0009281978
04/25/2023 October 2022 TX0009281914
04/26/2023 January 2023 TX0009282360
04/26/2023 December 2022 TX0009282860
04/26/2023 March 2023 TX0009282828
04/26/2023 February 2023 TX0009282404
05/15/2023 August 2022 TX0009261481
08/15/2023 April 2023 TX0009308847
01/10/2024 September 2023 TX0009362088
01/10/2024 July 2023 TX0009362398
01/10/2024 August 2023 TX0009362314
01/10/2024 October 2023 TX0009362049
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 1 of 16

EXHIBIT I
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 2 of 16
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 3 of 16
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 4 of 16
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 5 of 16
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 6 of 16

Reg. No. 5,254,460 The Denver Post, LLC (DELAWARE LIMITED LIABILITY COMPANY)
101 West Colfax Avenue
Registered Aug. 01, 2017 Denver, CO 80202

CLASS 35: Advertising and advertisement services; advertising and marketing; advertising
Int. Cl.: 35 services, namely, preparing and disseminating advertising for others; advertising and
marketing services, namely, promoting the goods and services of others; advertising and
Service Mark marketing services, namely, promoting and marketing the goods and services of others
through all public communication means; creation, development, operation, administration
Principal Register and management of advertising campaigns for others; advertising services, namely, preparing
and disseminating advertising for others via the Internet, mobile applications, email messages,
on websites, in printed publications and via digital media and publications; advertising and
marketing services provided by means of indirect methods of marketing communications,
namely, social media, search engine marketing, inquiry marketing, internet marketing, mobile
marketing, blogging and other forms of passive, sharable or viral communications channels;
classified advertising services

FIRST USE 5-18-2016; IN COMMERCE 5-18-2016

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY


PARTICULAR FONT STYLE, SIZE OR COLOR

OWNER OF U.S. REG. NO. 2816508, 2313450, 1919631

No claim is made to the exclusive right to use the following apart from the mark as shown:
"MEDIA"

SEC. 2(F) As to "DENVER POST" has become distinctive of the goods/services as evidenced
by the ownership on the Principal Register for the same mark for sufficiently similar
goods/services of active U.S. Registration No(s). 1919631, 2313450, 2816508, 3878548,
3915900, and 4201590; DENVER POST has become distinctive of the goods/services
through the applicant's substantially exclusive and continuous use of the mark in commerce
that the U.S. Congress may lawfully regulate for at least the five years immediately before the
date of this statement.

SER. NO. 87-143,536, FILED 08-18-2016


CHARLES L JENKINS JR, EXAMINING ATTORNEY
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 7 of 16

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION


WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*


What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*


What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an


extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5254460
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 8 of 16

Reg. No. 5,240,678 San Jose Mercury-News, LLC (CALIFORNIA LIMITED LIABILITY COMPANY)
4 North 2nd Street
Registered Jul. 11, 2017 San Jose, CA 95113

CLASS 9: Downloadable electronic publications in the nature of newspapers; downloadable


Int. Cl.: 9 software in the nature of an application for obtaining news, information, commentary, and
content of the type found in general interest publications on stationary and mobile devices;
Trademark computer application software for mobile phones and hand held devices, namely, software for
obtaining news, information, commentary, and content of the type found in general interest
Principal Register publications; downloadable electronic newspapers in the field of current events, cultural
events, general interest

FIRST USE 4-5-2016; IN COMMERCE 4-5-2016

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY


PARTICULAR FONT STYLE, SIZE OR COLOR

No claim is made to the exclusive right to use the following apart from the mark as shown:
"NEWS"

SER. NO. 87-247,005, FILED 11-23-2016


KIM TERESA MONINGHOFF, EXAMINING ATTORNEY
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 9 of 16

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION


WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*


What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*


What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an


extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5240678
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 10 of 16

Reg. No. 5,240,681 San Jose Mercury-News, LLC (CALIFORNIA LIMITED LIABILITY COMPANY)
4 North 2nd Street
Registered Jul. 11, 2017 San Jose, CA 95113

CLASS 16: Newspaper of general circulation


Int. Cl.: 16
FIRST USE 4-5-2016; IN COMMERCE 4-5-2016
Trademark
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
Principal Register PARTICULAR FONT STYLE, SIZE OR COLOR

No claim is made to the exclusive right to use the following apart from the mark as shown:
"NEWS"

SER. NO. 87-247,028, FILED 11-23-2016


KIM TERESA MONINGHOFF, EXAMINING ATTORNEY
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 11 of 16

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION


WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*


What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*


What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an


extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5240681
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 12 of 16

Reg. No. 5,240,683 San Jose Mercury-News, LLC (CALIFORNIA LIMITED LIABILITY COMPANY)
4 North 2nd Street
Registered Jul. 11, 2017 San Jose, CA 95113

CLASS 35: Advertising and advertisement services


Int. Cl.: 35
FIRST USE 4-5-2016; IN COMMERCE 4-5-2016
Service Mark
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
Principal Register PARTICULAR FONT STYLE, SIZE OR COLOR

No claim is made to the exclusive right to use the following apart from the mark as shown:
"NEWS"

SER. NO. 87-247,043, FILED 11-23-2016


KIM TERESA MONINGHOFF, EXAMINING ATTORNEY
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 13 of 16

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION


WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*


What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*


What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an


extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5240683
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 14 of 16

Reg. No. 5,240,684 San Jose Mercury-News, LLC (CALIFORNIA LIMITED LIABILITY COMPANY)
4 North 2nd Street
Registered Jul. 11, 2017 San Jose, CA 95113

CLASS 41: Providing on-line non-downloadable newspapers; Providing a website featuring


Int. Cl.: 41 online non-downloadable articles, photos, videos, and blogs in the fields of current event
news, social events, education, finance, government, health, religion, shopping, sports,
Service Mark technology, transportation, travel, business, commentary, home and garden, investigations,
obituaries, classifieds and weather
Principal Register
FIRST USE 4-5-2016; IN COMMERCE 4-5-2016

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY


PARTICULAR FONT STYLE, SIZE OR COLOR

No claim is made to the exclusive right to use the following apart from the mark as shown:
"NEWS"

SER. NO. 87-247,049, FILED 11-23-2016


KIM TERESA MONINGHOFF, EXAMINING ATTORNEY
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 15 of 16

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION


WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years*


What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods*


What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an


extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5240684
Case 1:24-cv-03285 Document 1-9 Filed 04/30/24 Page 16 of 16
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 1 of 59

EXHIBIT J
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 2 of 59

EXAMPLES OF GPT-4 MEMORIZING CONTENT


FROM THE PUBLISHERS

The following are examples of situations where OpenAI’s GPT-4 model was trained on and memorized
articles from the Publishers. Each example focuses on a single news article. Examples were produced by
breaking the article into two parts. The first part of the article is given to GPT-4 as a prompt, and GPT-4
replies by writing its own version of the remainder of the article. The following system prompt was used
for each example: “I’ll give you the first part of an article. Complete the article with the correct original
ending.”
In each case, we observe that the output of GPT-4 contains spans that are identical to the actual text of
the article from the Publisher. For each example, we provide the following:
• The URL of the online version of the article.
• The prompt that was given to GPT-4. This prompt comprises the beginning of an article from the
Publisher.
• The response from GPT-4. In each example, the GPT-4 assistant replies to the prompt by writing
a verbatim portion of the original article from the Publisher from its memory.
• The original end of the article, as it appears on the Publisher’s website. Text is depicted in red font
when it appears identically in both the GPT-4 output and the source article from the Publisher.

1
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 3 of 59

Example 1: President Trump’s Muslim ban excludes countries linked to his sprawling
business empire
https://www.nydailynews.com/2017/02/01/president-trumps-muslim-ban-excludes-countries-
linked-to-his-sprawling-business-empire/
Prompt (taken from article):
President Trump’s most recent executive order effectively bans citizens of seven Muslim-majority
countries from entering the U.S. for at least 90 days — but some Muslim countries were spared from the
order’s blacklist, even though they have deep-seated ties to terrorism. Conspicuously, Trump doesn’t
hold any business interests in any of the countries on the list, but holds major stakes in several of those
excluded from it, records show. Friday’s

Model output: Text from the New York Daily News:


executive order, signed at the Pentagon, suspends executive order, signed at the Pentagon, suspends
the issuing of U.S. visas or travel permits to people the issuing of U.S. visas or travel permits to people
from Iran, Iraq, Libya, Somalia, Sudan, Syria and from Iran, Iraq, Libya, Somalia, Sudan, Syria and
Yemen. Not a single American was killed on U.S. Yemen. Not a single American was killed on U.S.
soil by citizens from any of those countries between soil by citizens from any of those countries between
1975 and 2015, according to statistics tallied by the 1975 and 2015, according to statistics tallied by the
conservative-leaning Cato Institute. conservative-leaning Cato Institute. However, the
However, the same set of statistics show that nearly same set of statistics show that nearly 3,000 Amer-
3,000 Americans were killed by citizens from Saudi icans were killed by citizens from Saudi Arabia, the
Arabia, the United Arab Emirates, Egypt and United Arab Emirates and Egypt in the same time
Turkey in the same time period — with the vast period — with the bulk of those killed being victims
majority of those killed being victims of the 9/11 of the 9/11 attacks. Yet, people from those three
attacks. Yet, people from those four countries are countries are still welcome to apply for U.S. visas
still welcome to apply for U.S. visas and travel per- and travel permits. In a striking parallel, Trump’s
mits. sprawling business empire — which he has refused
In a striking parallel, Trump’s sprawling business to rescind ownership of — holds multi-million dol-
empire — which he has refused to rescind owner- lar licensing and development deals in all of those
ship of — holds multi-million dollar licensing and countries, raising potential conflict of interest con-
development deals in all of those countries, raising cerns and alarming questions over what actually
potential conflict of interest concerns and alarming
questions over what actually

2
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 4 of 59

Example 2: President Trump chooses inexperienced woman who planned his son Eric’s
wedding to run N.Y. federal housing programs
https://www.nydailynews.com/2017/06/15/president-trump-chooses-inexperienced-woman-who-
planned-his-son-erics-wedding-to-run-ny-federal-housing-programs/
Prompt (taken from article):
She’s arranged tournaments at Trump golf courses, served as the liaison to the Trump family during his
presidential campaign, and even arranged Eric Trump’s wedding. Now President Trump has appointed
longtime loyalist Lynne Patton — who has zero housing experience and claims a law degree the school
says she never earned — to run the office that oversees federal housing programs in New York.

Model output: Text from the New York Daily News:


Patton was appointed Wednesday to head up the Patton was appointed Wednesday to head up the
U.S. Department of Housing and Urban Develop- U.S. Department of Housing and Urban Develop-
ment’s Region II, which includes New York and New ment’s Region II, which includes New York and
Jersey, where she’ll oversee distribution of billions of New Jersey, where she’ll oversee distribution of bil-
taxpayer dollars. lions of taxpayer dollars. Patton’s tight relation-
Patton’s tight relationship with the Trump clan ship with the Trump clan dates back to 2009, when
dates back to 2009, when she began serving as the she began serving as the family’s “event planner.”
family’s “event planner.” “Responsible for organiz- “Responsible for organizing, executing and assist-
ing, executing and assisting with upscale events and ing with upscale events and celebrity golf tourna-
celebrity golf tournaments,” her LinkedIn profile ments,” her LinkedIn profile says. “Handle celebrity
says. “Handle celebrity talent acquisition for var- talent acquisition for various marketing projects,
ious marketing projects, philanthropic events and philanthropic events and golf tournaments.” From
golf tournaments.” 2011 through January, she also helped run the Eric
From 2011 through January, she also helped run the Trump Foundation, a charity that’s now under in-
Eric Trump Foundation, a charity that’s now under vestigation by state Attorney General Eric Schnei-
investigation by state Attorney General Eric Schnei- derman. She also claims on her LinkedIn page
derman. to have obtained a juris doctorate degree in 2000
She also claims on her LinkedIn page to have ob- from Quinnipiac University School of Law in Con-
tained a juris doctorate degree in 2000 from Quin- necticut. Next to the J.D. notation is written (N/A)
nipiac University School of Law in Connecticut. without explanation. On Thursday school registrar
Next to the J.D. notation is written (N/A) without Jim Benson said Patton attended for two semesters
explanation. but did not graduate. She also listed Yale Univer-
On Thursday school registrar Jim Benson said Pat- sity but HUD officials couldn’t explain why that was
ton attended for two semesters but did not graduate. there. Patton, who begins her Region II job July 5,
She also listed Yale University but HUD officials did not return calls seeking comment.
couldn’t explain why that was there. Patton, who As head of the biggest HUD regional office in the
begins her Region II job July 5, did not return calls U.S., Patton will oversee distribution of billions in
seeking comment. cash to public housing authorities — including NY-
As head of the biggest HUD regional office in the CHA — as well as tens of thousands of rental vouch-
U.S., Patton will oversee distribution of billions in ers and block grants that fund housing inspections
cash to public housing authorities — including NY- and senior citizen programs. Patton is one of the
CHA — as well as tens of thousands of rental vouch- handful of African Americans within inner circle and
ers and block grants that fund housing inspections a passionate Trump promoter. Last year she made
and senior citizen programs. a video entitled "I’m proof Donald Trump isn’t a
Patton is one of the handful of African Americans bigot.” Trump first placed her as a White House
within Trump’s inner circle and a passionate Trump liaison at HUD in February. While there, she’s fired
promoter. Last year she made a video entitled "I’m off multiple
proof Donald Trump isn’t a bigot.”
Trump first placed her as a White House liaison at
HUD in February. While there, she’s fired off mul-
tiple
3
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 5 of 59

Example 3: ‘He couldn’t move, and the rats were crawling all over him,’ says brother of
man who plunged into Bronx sidewalk sinkhole
https://www.nydailynews.com/new-york/nyc-crime/ny-bronx-man-sinkhole-rats-20201027-
75a72h46hragbi5kte6zurc554-story.html
Prompt (taken from article):
A Bronx man who plummeted 15 feet after a sinkhole opened underneath him had to

Model output: Text from the New York Daily News:


deal with a swarm of scurrying rats as he waited for deal with a swarm of scurrying rats as he waited for
help, his brother told the Daily News. help, his brother told the Daily News.
Leonard Shoulders, 33, was waiting for a bus on Leonard Shoulders, 33, was waiting for a bus on
Third Ave. near E. 183rd St. in Belmont Satur- Third Ave. near E. 183rd St. in Belmont Satur-
day afternoon when the concrete sidewalk suddenly day afternoon when the concrete sidewalk suddenly
cracked open and swallowed cracked open and swallowed

4
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 6 of 59

Example 4: NYC cops find decapitated, limbless man in million-dollar condo; electric saw
found next to torso
https://www.nydailynews.com/new-york/nyc-crime/ny-headless-torso-found-manhattan-
20200714-rz25uxzsejgrxnsk4rd22vf7hq-story.html
Prompt (taken from article):
The limbless, headless torso of a millionaire tech entrepreneur was found

Model output: Text from the New York Daily News:


inside his swanky Manhattan condo Tuesday after- inside his swanky Manhattan condo Tuesday after-
noon — an electric saw lying next to the remains, noon — an electric saw lying next to the remains,
police said. police said.
Police made the grisly discovery in a building on Police made the grisly discovery in a building on
E. Houston St. at Suffolk St. on the Lower East E. Houston St. at Suffolk St. on the Lower East
side about 3:30 p.m. Cops found contractor bags side about 3:30 p.m. Cops found contractor bags
near the torso, sources said, but didn’t immediately near the torso, sources said, but didn’t immediately
open them to see if the body parts were inside. open them to see if the body parts were inside.
The victim was identified as Fahim Saleh, 33, who An NYPD official said investigators believe the vic-
bought the condo for $2.25 million last year. Saleh, tim is tech entrepreneur Fahim Saleh, 33, who
a venture capitalist, was the CEO of a motorbike- bought the condo for $2.25 million last year. Saleh,
hailing company in Nigeria, called Gokada. a website developer turned venture capital, is the
Detectives were waiting for fingerprint and forensics CEO of a motorcycle-sharing company in Lagos,
tests on the body Nigeria.
Fahim Saleh
NYPD spokesman Sgt. Carlos Nieves said all of the
body parts were found at the scene but declined to
give specifics on where.
“We have a torso, a head that’s been removed, arms,
and legs. Everything is still on the scene. We don’t
have a motive,” he said.
Detectives were waiting for fingerprint and forensics
tests on the body

5
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 7 of 59

Example 5: A spike in New Yorkers ingesting household cleaners following Trump’s


controversial coronavirus comments
https://www.nydailynews.com/coronavirus/ny-coronavirus-new-yorkers-household-
cleaners-trump-20200425-rnaqio5dyfeaxmthxx2vktqa5m-story.html?fbclid=
IwAR3B4mVVaTfC5eVswNBs2JQb9R1dD1i4vjEf_cXDUJ8OtbDAySd0TC4uxS0
Prompt (taken from article):
An unusually high number of New Yorkers contacted city health authorities over fears that they had
ingested bleach

Model output: Text from the New York Daily News:


or other household cleaners in the 18 hours that fol- or other household cleaners in the 18 hours that fol-
lowed President Trump’s bogus claim that inject- lowed President Trump’s bogus claim that inject-
ing such products could cure coronavirus, the Daily ing such products could cure coronavirus, the Daily
News has learned. News has learned.
The Poison Control Center, a subagency of the city’s The Poison Control Center, a subagency of the city’s
Health Department, managed a total of 30 cases of Health Department, managed a total of 30 cases of
possible exposure to disinfectants between 9 p.m. possible exposure to disinfectants between 9 p.m.
Thursday and 3 p.m. Friday, a spokesman said. Thursday and 3 p.m. Friday, a spokesman said.
None of the people who reached out died or None of the people who reached out died or required
required hospitalization, but they had abnormal hospitalization, the spokesman said. But compared
symptoms like difficulty breathing, burning sensa- to last year, the number of cases was worthy of a
tions, vomiting, and even temporary loss of vision, double-take.
the spokesman said. According to data obtained by The News, the Poison
In comparison, the Poison Control Center only han- Control Center only handled 13 similar cases in the
dled 13 similar cases in the same 18-hour period last same 18-hour period last year.
Moreover, out of the cases reported between Thurs-
day and Friday, nine were specifically about possible
exposure to Lysol. Ten were in regard to bleach
and 11 about household cleaners in general, the
spokesman said.
In

6
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 8 of 59

Example 6: WEEK IN NEWS: Repeat robbers, classes commence, overtime outrage,


tawdry teacher
https://www.nydailynews.com/new-york/ny-week-in-news-20201206-6v72gaqgsncchfnr2xj5tcxh2i-
story.html
Prompt (taken from article):
No one covers the city like the Daily News. For nearly 100 years, New York’s Hometown Newspaper
has been your eyes and ears

Model output: Text from the New York Daily News:


— and your voice. — and your voice.
Do you have a story you think we should tell? Do you have a story you think we should tell?
Call us at (212) 210-NEWS or email us at Call us at (212) 210-NEWS or email us at
news@nydailynews.com. This is your paper, and we news@nydailynews.com. This is your paper, and we
are committed to covering the issues that matter to are committed to covering the issues that matter to
you. Here are some of our top stories from you. Here are some of our top stories from

7
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 9 of 59

Example 7: Trump expected to send new federal force to Chicago this week to battle
violence, but plan’s full scope is a question mark
https://www.chicagotribune.com/2020/07/20/trump-expected-to-send-new-federal-force-to-
chicago-this-week-to-battle-violence-but-plans-full-scope-is-a-question-mark/
Prompt (taken from article):
Chicago may see an influx of federal

Model output: Text from the Chicago Tribune:


agents as soon as this week as President Donald agents as soon as this week as President Donald
Trump readies to make good on repeated pledges he Trump readies to make good on repeated pledges he
would try to tamp down violence here, a move that would try to tamp down violence here, a move that
would come amid growing controversy nationally would come amid growing controversy nationally
about federal force being used in American cities. about federal force being used in American cities.
U.S. Department of Homeland Security, for exam- U.S. Department of Homeland Security, for ex-
ple, is crafting plans to deploy about 150 federal ample, is crafting plans to deploy about 150 federal
agents to the city this week, the Chicago Tribune agents to the city this week, the Chicago Tribune has
has learned. learned. The Homeland Security Investigations, or
The Homeland Security Investigations, or HSI, HSI, agents are set to assist other federal law en-
agents are set to assist other federal law enforcement forcement and Chicago police in crime-fighting ef-
and Chicago police in crime-fighting efforts, accord- forts, according to sources familiar with the matter,
ing to sources familiar with the matter, though a though a specific plan on what the agents will be
specific plan on what the agents will be doing had doing — and what their limits would be — had not
not been made been made

8
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 10 of 59

Example 8: Lori Lightfoot elected Chicago mayor, making her the first
African-American woman to lead the city
https://www.chicagotribune.com/2019/04/02/lori-lightfoot-elected-chicago-mayor-making-
her-the-first-african-american-woman-to-lead-the-city/
Prompt (taken from article):
Lori Lightfoot won a resounding victory Tuesday

Model output: Text from the Chicago Tribune:


night to become both the first African-American night to become both the first African-American
woman and openly gay person elected mayor of woman and openly gay person elected mayor of
Chicago, dealing a stinging defeat to a political Chicago, dealing a stinging defeat to a political
establishment that has reigned over City Hall for establishment that has reigned over City Hall for
decades. decades. After waging a campaign focused on
After waging a campaign focused on upending the upending the vaunted Chicago political machine,
vaunted Chicago political machine, Lightfoot dis- Lightfoot dismantled one of its major cogs by dis-
mantled one of its major cogs by dispatching Cook patching Cook County Board President Toni Preck-
County Board President Toni Preckwinkle, whose winkle, whose candidacy had been hobbled in part
decades-long career in politics had been boosted by by an anti-incumbent mood among voters and an
an army of public employees and labor unions. ongoing federal corruption investigation at City
With roughly 97% of the city’s precincts reporting, Hall. Lightfoot’s campaign, which started last May
Lightfoot had swept all 50 of Chicago’s wards, win- as a long-shot bid to replace the city’s clouted pol-
ning 74% of the unofficial vote to 26% for Preck- itics with inclusive change, took the former federal
winkle, a 28-year officeholder who prior to her eight prosecutor and first-time candidate from toiling in
years as the county’s chief executive served 19 years relative political obscurity to toppling the head of
as a Hyde Park alderman. the Cook County Democratic Party. “Today, you
Lightfoot will be sworn in as Chicago’s 56th mayor did more than make history,” Lightfoot told hun-
on May 20 while Preckwinkle will return to her third dreds of supporters at the Hilton Chicago on Tues-
term running the county after a humiliating defeat day night. “You created a movement for change.”
that included losing her own ward. With roughly 97 percent of the city’s precincts re-
"I’m not a person who decided I would climb the porting, Lightfoot had swept all 50 of Chicago’s
ladder of a corrupt political system, and I’m not a wards, winning 74 percent of the unofficial vote to
person who made backroom deals to gain power," 26 percent for Preckwinkle, a 28-year officeholder
Lightfoot said to the thunderous applause of sup- who prior to her eight years as the county’s chief
porters at her victory party. "We can and we will executive served 19 years as a Hyde Park alderman.
break this city’s cycle of corruption. People said this Lightfoot will be sworn in as Chicago’s 56th mayor
day would never come. But it’s here." on May 20 while Preckwinkle will return to her third
In her concession speech, Preckwinkle congratulated term running the county after a humiliating defeat
Lightfoot on her victory. "This may not be the out- that included losing her own 4th Ward by 20 points.
come we wanted, but while I may be disappointed, Results updated as of Apr. 3, 3:48 PM. 2029 of
I’m not disheartened," she said. "For one thing, this 2069 precincts reporting Click here for complete re-
is clearly a historic night. Not long ago, two African- sults “This may not be the outcome we wanted, but
American women vying for this position would have while I may be disappointed, I’m not disheartened,"
been unthinkable. And while it may be true that Preckwinkle told supporters at a Hyde Park night-
we took different paths to get here, tonight is about club. “For one thing, this is clearly a historic night.
the path Not long ago, two African- American women vying
for this position would have been unthinkable. And
while it may be true we took different paths to get
here, tonight is about the path

9
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Example 9: Finding hope after tragedy: Wife’s stroke left dad with newborn triplets a
year ago
https://www.chicagotribune.com/2019/06/12/finding-hope-after-tragedy-wifes-stroke-left-
dad-with-newborn-triplets-a-year-ago/
Prompt (taken from article):
Charlie Whitmer’s red-headed, blue-eyed triplets giggle and crawl

Model output: Text from the Chicago Tribune:


as they explore their West Town home. One stands as they explore their West Town home. One stands
up against a large front window, hands pressed to up against a large front window, hands pressed to
the glass, looking out on the street below. the glass, looking out to the street below. There’s
There’s no shortage of people to help Charlie — a no shortage of people to help Charlie — a stay-
stay-at-home dad — with the awesome and inher- at-home dad — with the awesome and inherently
ently chaotic responsibility of caring for three ba- chaotic responsibility of caring for three babies. His
bies. His house is often filled with house is often filled with

10
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 12 of 59

Example 10: ‘Fort Lori’: Chicago police ban protests on Mayor Lori Lightfoot’s block,
order arrests for anyone who won’t leave
https://www.chicagotribune.com/2020/08/20/fort-lori-chicago-police-ban-protests-on-
mayor-lori-lightfoots-block-order-arrests-for-anyone-who-wont-leave/
Prompt (taken from article):
The Chicago Police Department has effectively banned protesters from demonstrating on Mayor

Model output: Text from the Chicago Tribune:


Lori Lightfoot’s block in the Logan Square neighbor- Lori Lightfoot’s block in the Logan Square neighbor-
hood, ordering officers to arrest anyone who refuses hood, ordering officers to arrest anyone who refuses
to leave, the Tribune has learned. to leave, the Tribune has learned. The directive
The directive surfaced in a July email from then- surfaced in a July email from then-Shakespeare Dis-
District Commander Melvin Roman to officers un- trict Commander Melvin Roman to officers under
der his command. It did not distinguish between his command. It did not distinguish between the
the peaceful protestors Lightfoot regularly says she peaceful protesters Lightfoot regularly says she sup-
supports and those who might intend to be destruc- ports and those who might intend to be destructive,
tive, but ordered that after a warning is given to but ordered that after a warning is given to demon-
demonstrators, strators,

11
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Example 11: South suburban mayor charged in red-light camera bribery scheme
https://www.chicagotribune.com/2020/08/07/south-suburban-mayor-charged-in-red-light-
camera-bribery-scheme/
Prompt (taken from article):
When red-light cameras came to Crestwood in 2016, the village quickly became the top-ticketing
Chicago suburb, issuing more than $6 million in fines a year. Now four years later, its mayor has been
indicted on federal charges that he accepted bribes to promote the cameras, the latest development in
a wide- ranging political corruption probe. According to federal prosecutors, Lou Presta was caught on
a March 2018 recording accepting an envelope with $5,000 cash from a representative of the red-light
camera firm, and then lied to the FBI and IRS when asked about it that September. Presta, 69, is

Model output: Text from the Chicago Tribune:


charged with three counts of using a facility in in- charged with three counts of using a facility in inter-
terstate commerce in aid of bribery and official mis- state commerce in aid of bribery and official miscon-
conduct, two counts of willfully filing a false income duct, two counts of willfully filing a false income tax
tax return, one count of willfully failing to file an return, one count of willfully failing to file an income
income tax return, and one count of making false tax return and one count of making false statements
statements to the FBI and IRS. to the FBI and IRS.

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Example 12: Mayor Lori Lightfoot fires Chicago’s police superintendent weeks before
his retirement: ‘Eddie Johnson intentionally lied to me’
https://www.chicagotribune.com/2019/12/03/mayor-lori-lightfoot-fires-chicagos-police-
superintendent-weeks-before-his-retirement-eddie-johnson-intentionally-lied-to-me/
Prompt (taken from article):
Mayor Lori Lightfoot fired police Superintendent Eddie Johnson effective immediately Monday for
intentionally misleading her and the public about his conduct when he was found asleep in his running
vehicle at a stop sign after a late weeknight out in October. “This moment needs to be a turning point
for the Chicago Police Department and the way things are done in this city,” said Lightfoot, emphasizing
that a “culture change” must take place. The stunning announcement came just weeks after Lightfoot
held what she referred to Monday as “a celebratory press conference” to announce Johnson’s retirement
by year’s end after about 31/2 years at the helm. Former Los Angeles police Chief Charlie Beck,
previously named Johnson’s interim successor, took control of the beleaguered department after flying
into Chicago on Monday afternoon. He and the mayor separately met with the department’s top brass.
Sources told the Chicago Tribune that the city

13
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 15 of 59

Model output: Text from the Chicago Tribune:


’s inspector general’s office, which has been investi- inspector general’s office, which has been investi-
gating the October incident, obtained video footage gating the October incident, obtained video footage
showing Johnson drinking for a few hours on the showing Johnson drinking for a few hours on the
evening of Oct. 16 with a woman who was not his evening of Oct. 16 with a woman who was not
wife at the Ceres Cafe, a popular restaurant and bar his wife at the Ceres Cafe, a popular restaurant
at the Chicago Board of Trade building. and bar at the Chicago Board of Trade building.
Lightfoot declined to go into specifics about the in- Later that night, when officers responded to a
spector general’s ongoing investigation but said it 911 call near Johnson’s home in the Bridgeport
revealed actions by Johnson that are "intolerable." neighborhood about 12:30 a.m. Oct. 17, Johnson
She said Johnson "engaged in conduct that is not rolled down the window on his police vehicle part-
only unbecoming,but demonstrated a series of ethi- way, flashed his superintendent’s badge and drove
cal lapses and flawed decision-making off, sources said. A Ceres employee who identified
himself as a general manager declined to comment
Monday. On Monday, Lightfoot told reporters she
had reviewed the inspector general’s report into the
incident as well as videotaped evidence that left her
with no choice but to fire Johnson. “I saw things
that were inconsistent with what Mr. Johnson had
told me personally and what he revealed to members
of the public,” she said. With the inspector general’s
report still not public, Lightfoot declined to be more
specific about what the videotaped evidence showed
but hinted that it would be hurtful to Johnson’s
family. “While at some point the IG’s report may
become public and those details may be revealed, I
don’t feel like it’s appropriate or fair to Mr. John-
son’s wife or children to do so at this time,” she said.
Sources said Lightfoot moved to fire Johnson before
the superintendent had even been interviewed by the
inspector general’s office as part of its investigation.
The mayor said she personally delivered the news
Monday morning to Johnson, the fourth of the last
six superintendents to be fired or resign amid scan-
dal. She gave three reasons for dumping him: —
That he “engaged in conduct that is not only unbe-
coming but demonstrated a series of ethical lapses
and flawed decision-making

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Example 13: Flood insurance reforms loom


http://www.orlandosentinel.com/classified/realestate/os-bz-flood-insurance-20170724-
story.html
Prompt (taken from article):
Florida wades deeper into hurricane season

Model output: Text from the Orlando Sentinel:


as the debate heightens over what to do with the as the debate heightens over what to do with the
deeply indebted National Flood Insurance Program deeply indebted National Flood Insurance Program
and its coverage of properties prone to repeated and its coverage of properties prone to repeated
flooding. flooding.
The Sunshine The Sunshine

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Example 14: Florida father killed in online-dating setup


https://www.orlandosentinel.com/news/breaking-news/os-murder-robbery-online-dating-
20160822-story.html
Prompt (taken from article):
The night before police found Adam Hilarie

Model output: Text from the Orlando Sentinel:


dead in his kitchen, the 27-year-old Central Florida dead in his kitchen, the 27-year-old Central Florida
father went bowling with a woman he met through father went bowling with a woman he met through
the online dating site PlentyOfFish, Auburndale po- the online dating site PlentyOfFish, Auburndale po-
lice said Monday. lice said Monday.
They went back to his place, and she texted him They went back to his place, and she texted him
later: "I had a good time and would like to see you later: I had a good time and would like to see you
again." She saw him the following night, when on again.
Friday she brought three men to rob Hilarie of TVs, She saw him the next night, when on Friday she
an Xbox and an iPhone, and one of them shot him brought three men to rob Hilarie of TVs, an Xbox
in the head, Deputy Chief Andy Ray said at a news and an iPhone, and one of them shot him in the
conference. head, Deputy Chief Andy Ray said at a news con-
"In cases like this, it’s easy for us to put ourselves ference.
in the shoes of the victim," Ray said. "We see this "In cases like this, it’s easy for us to put ourselves in
person who was obviously murdered in cold blood the shoes of the family,” Ray said, as he detailed the
and it’s easy to feel for his family." arrest of four people in connection with the killing
Investigators got a break in the case after a witness — including 18-year-old Hailey Bustos, who went on
reported seeing Hilarie with a young woman Thurs- the date with him.
day night, and Winter Haven police picked up Bus- Andre Warner, 26, Gary Gray, 31, and Joshua
tos in a separate burglary over the weekend. After Ellington, 26, were also also arrested on charges
her arrest, Bustos told police that Hilarie had been of conspiracy to commit robbery, robbery with a
shot, officials said. firearm and first-degree murder. Ray said he didn’t
Andre Warner, 26, Gary Gray, 31, and Joshua know how the robbery escalated.
Ellington, 26, were also arrested on charges of con- “Hilarie was begging for his life, he was not putting
spiracy to commit robbery, robbery with a firearm up any kind of fight, and was telling them that he
and first-degree murder, the news release said. had a 5-year-old daughter,” according to arrest re-
During the robbery, one of the men allegedly shot ports.
Hilarie in the head. "Hilarie was begging for his life, Social media photos show Hilarie suited up in box-
he was not putting up any kind of fight, and was ing gloves and a robe. He posted multiple photos
telling them that he had a 5-year-old of his daughter on his Facebook page, calling her
“Princess.” Friends and family set up a fundraiser
to help pay for funeral expenses.
“Each and every one of you know he was fun to
be around,” Hilarie’s brother said at a vigil held for
him, which was videotaped and posted on Facebook.
“No matter what we did, we always had a good time
and he always had that smile. This isn’t easy.”
Investigators got a break in the case after a wit-
ness reported seeing Hilarie with a young woman
Thursday night, and Winter Haven police picked up
Bustos in a separate burglary over the weekend.

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Example 15: Private schools’ curriculum downplays slavery, says humans and dinosaurs
lived together
https://www.orlandosentinel.com/news/education/os-voucher-school-curriculum-20180503-
story.html
Prompt (taken from article):
Some private schools in Florida that rely on public funding teach students that dinosaurs and humans
lived together, that God’s intervention prevented Catholics from dominating North America and that
slaves who “knew Christ” were better off than free men who did not.
The lessons taught at these schools come from three Christian publishing companies whose textbooks
are popular on many of about 2,000 campuses that accept, and often depend on, nearly $1 billion in
state scholarships, or vouchers.
At the Orlando Sentinel’s request, educators from Florida colleges

Model output: Text from the Orlando Sentinel:


and school districts reviewed textbooks and work- and school districts reviewed textbooks and work-
books from these publishers, looking at elementary books from these publishers, looking at elementary
reading and math, middle school social studies and reading and math, middle school social studies and
high school biology materials. They found numer- high school biology materials.
ous instances of distorted history and science lessons They found numerous instances of distorted history
that are outside mainstream academics. The books and science lessons that are outside mainstream aca-
denounce evolution as untrue, for example, and one demics. The books denounce evolution as untrue,
shows a cartoon of men and dinosaurs together, for example, and one shows a cartoon of men and di-
telling students the Biblical Noah likely brought nosaurs together, telling students the Biblical Noah
baby dinosaurs onto his ark. The science books, likely brought baby dinosaurs onto his ark. The sci-
they added, seem to discourage students from ence books, they added, seem to discourage students
from

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Example 16: Lockheed Martin gives first look into where astronauts may live on missions
to deep space
http://www.orlandosentinel.com/business/os-lockheed-space-habitat-20180815-story.html
Prompt (taken from article):
KENNEDY SPACE CENTER — A massive cylindrical habitat may one day house up to four astro-
nauts as they make the trek to

Model output: Text from the Orlando Sentinel:


deep space. Lockheed Martin gave a first look at deep space.
what one of these habitats might look like on Thurs- Lockheed Martin gave a first look at what one
day at the Kennedy Space Center, where the com- of these habitats might look like Thursday at the
pany is under contract with NASA to build a pro- Kennedy Space Center, where the aerospace giant
totype of the living is under contract with NASA to build a prototype
of the living

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Example 17: Kayla, the orca at SeaWorld Orlando, died from lung disease
https://www.orlandosentinel.com/business/tourism/os-cfb-seaworld-kayla-cuse-20190520-
jzrjtc7dargjtnx7gp3okrl3nu-story.html
Prompt (taken from article):
Kayla, the 30-year-old killer whale at SeaWorld Orlando that unexpectedly died

Model output: Text from the Orlando Sentinel:


in January, succumbed to lung disease, the theme in January, fell victim to lung disease, the theme
park company said Monday. park company said Monday.
SeaWorld released the cause of death following an SeaWorld released the cause of death following an
investigation into what had suddenly killed the orca. investigation into what had suddenly killed the orca.
She had seemed healthy until over the weekend of She had seemed healthy until over the course of one
January 26 when her appetite began to decrease. weekend when her condition worsened. Veterinari-
Despite receiving round-the-clock care from animal ans who gave round-the-clock care couldn’t save her.
health experts, Kayla died on January 28. "We determined Kayla died of lung disease, which
"Kayla died of lung disease, which presented very presented very quickly in her case," said Dr. Chris
quickly in her case," SeaWorld said in a statement. Dold, SeaWorld’s Chief Zoological Officer in a state-
"Despite her care team’s efforts, her condition pro- ment Monday. “Lung disease is a common cause of
gressed rapidly and she passed away." illness and death seen in marine mammals in the
The company said that lung disease is a common wild, in human care and in those we rescue. It re-
cause of illness and death mains the leading cause of death for dolphins and
whales throughout the world.”
Her death leaves SeaWorld Orlando park with five
other orcas.
Kayla was born into captivity.
“As with all animals in our care, we will try to learn
from Kayla’s death,” Dold said in a statement

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Example 18: A Disney World tourist didn’t have a FastPass to Tower of Terror, so she
punched an employee and started pressing buttons
https://www.orlandosentinel.com/business/tourism/os-bz-disney-tourist-terror-20190722-
bf3kpc65ezhftixb4pbyzq5hem-story.html
Prompt (taken from article):
A Chicago tourist who was angry she didn’t have a FastPass to Tower of

20
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Model output: Text from the Orlando Sentinel:


Terror punched a Disney World cast member in the Terror ended up punching a Disney World cast mem-
face and began pushing buttons, which the employee ber in the face and began pushing buttons, which
warned could have affected the ride, according to a the employee warned could have affected the ride,
sheriff’s report. according to a sheriff’s report.
The 23-year-old woman wasn’t charged; the Disney The 23-year-old woman wasn’t charged; the Disney
worker didn’t want to press charges, said the Orange worker didn’t want to press charges, said the Orange
County Sheriff’s Office report. County Sheriff’s Office report.
The incident began July 13 when the Chicago The attack began in the evening of July 13 when the
woman and her group were upset their FastPasses Chicago woman and her group were upset their Fast-
weren’t valid for the popular ride at Hollywood Stu- Passes weren’t valid for the popular ride at Tower
dios,the sheriff’s report said. of Terror that often draws a long wait at Hollywood
A 23-year-old Disney worker offered to help them Studios.
with the FastPasses, but The incident did not happen in the elevator shaft
portion of the ride but in the pre-show area where
visitors are ushered into the creepy library to watch
“The Twilight Zone” host Rod Serling’s introduc-
tion.
A 23-year-old Disney worker offered to help them
with the FastPasses, but the group only became
more angry.
On her podium phone, the worker called for a su-
pervisor to request security.
That’s when the Chicago woman “began pushing
buttons on her ride podium,” the report said.
The Disney worker asked the Chicago woman to stop
and when she was ignored, she pushed the tourist’s
hand away from the buttons. She got a punch in
the face, the report said.
The scene kept escalating.
“The family continued to yell profanities and record
her with their phones,” the report said.
The woman and her group left Tower of Terror as
the worker spoke with security. But they were soon
found by security.
When the sheriff’s office responded to the call, the
worker’s eye was swelling, although she declined
treatment.
Disney has issued a lifetime ban on the Chicago
woman.
“We don’t tolerate unsafe behavior,” a Disney
spokeswoman said when reached for comment.
A man answered and said it was the wrong number
when the Sentinel attempted to reach the Chicago
woman through a phone number listed in the sher-
iff’s report

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Example 19: Schools’ culture of tolerance lets students like Nikolas Cruz slide
https://www.sun-sentinel.com/local/broward/parkland/florida-school-shooting/fl-florida-
school-shooting-discipline-20180510-story.html
Prompt (taken from article):
Broward Schools have grown so tolerant of

Model output: Text from the Sun Sentinel:


misbehavior that students like Nikolas Cruz are able misbehavior that students like Nikolas Cruz are able
to slide by for years without strict punishment for to slide by for years without strict punishment for
conduct that could be criminal. The culture of conduct that could be criminal.
leniency allows children to engage in an endless loop The culture of leniency allows children to engage in
of violations and second chances, creating a system an endless loop of violations and second chances,
where kids who commit the same offense for the 10th creating a system where kids who commit the same
time may be treated like it’s the first, according to offense for the 10th time may be treated like it’s the
records and interviews with first, a ccording t o r ecords a nd i nterviews with

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Example 20: Unprepared and overwhelmed: Detailed timeline shows 58 minutes of chaos
in Parkland | Investigation
http://www.sun-sentinel.com/local/broward/parkland/florida-school-shooting/fl-sfl-ne-
parkland-school-shooting-critical-moments-20181227-story.html
Prompt (taken from article):
Failures by the Broward County Sheriff’s Office and school district cost children their

Model output: Text from the Sun Sentinel:


lives at Marjory Stoneman Douglas High School. lives at Marjory Stoneman Douglas High School.
A gunman with an AR-15 fired the bullets, but a A gunman with an AR-15 fired t he b ullets, but
series of blunders, bad policies, sketchy training,and a series of blunders, bad policies, sketchy training
poor leadership helped him succeed. Information and poor leadership helped him succeed. Informa-
reported over 10 months by the South Florida Sun tion reported over 10 months by the South Florida
Sentinel reveals 58 minutes of chaos on campus Sun Sentinel reveals 58 minutes of chaos on campus
marked by no one taking charge, deputies dawdling, marked by no one taking charge, deputies dawdling,
false information spreading, communications para- false information spreading, communications para-
lyzed and children stranded with nowhere to hide. lyzed and children stranded with nowhere to hide.
To be sure, a number of teachers and police offi- To be sure, a number of teachers and police offi-
cers performed heroically. But an examination of cers performed heroically. But an examination of
the day’s events reveals that the sheriff’s office and the day’s events reveals that the sheriff’s office and
school district were unprepared for the school district were unprepared for the

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Example 21: GEO Group closes $360 million acquisition of Community Education Centers
http://www.sun-sentinel.com/business/fl-bz-geo-360m-nj-acquisition-close-20170406-
story.html
Prompt (taken from article):
GEO Group Inc. announced the closing

Model output: Text from the Sun Sentinel:


of its $360 million acquisition of Community Edu- of its $360 million acquisition of Community Edu-
cation Centers (CEC), a national provider of reha- cation Centers, a national provider of rehabilitative
bilitative services in reentry and in-prison treatment services in reentry and in-prison treatment facilities
facilities as well as management services for county, as well as management services for county, state,
state, and federal correctional and detention facili- and federal correctional and detention facilities.
ties.

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Example 22: Norwegian Air hiring U.S. pilots for Fort Lauderdale base
https://www.sun-sentinel.com/business/fl-norwegian-air-hires-us-pilots-20161010-
story.html
Prompt (taken from article):
To shore up growth in the United States in coming years, Norwegian Air Shuttle announced Monday
it is recruiting

Model output: Text from the Sun Sentinel:


and hiring American pilots for its crew base at Fort and hiring American pilots for its crew base at Fort
Lauderdale-Hollywood International Airport Lauderdale-Hollywood International Airport

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Example 23: Former doctor pleads guilty to manslaughter in 2013 overdose deaths
https://www.sun-sentinel.com/local/palm-beach/fl-former-doctor-plea-20160908-story.html
Prompt (taken from article):
A former pain doctor facing manslaughter charges over the 2013 overdose deaths of two Palm Beach
County patients reached a plea deal Thursday.
John Christensen — who had offices in West Palm
Model output: Text from the Sun Sentinel:
Beach, Port St. Lucie and Daytona Beach — Beach, Port St. Lucie and Daytona Beach —
pleaded guilty to two counts of manslaughter and pleaded guilty to two counts of manslaughter and
one count of conspiracy to commit health care fraud. one count of conspiracy to traffic oxycodone. He
faces up to five y ears i n p rison, u nder t he t erms of
the plea, according to the State Attorney’s Office.
Christensen also agreed to never practice medicine
again.
His sentencing is scheduled for Dec. 6.
Christensen, 64, initially faced first-degree murder
charges before they were changed to manslaughter.
The trial was set to begin Oct. 25, but that changed
with the agreement reached Thursday.
The charges involved the deaths of West Palm Beach
residents Florence Faye Garrett, 47, on Sept. 26,
2007, and Pawel Staniszewski, 31, on Aug. 7, 2008.
Christensen had been prescribing Garrett oxy-
codone as well as an anti-anxiety drug and he was
prescribing methadone and Xanax to Staniszewski,
according to prosecutors.
The prosecution had argued in court filings that
Christensen overprescribed pills in “bad faith and
without medical necessity.”
According to the investigation, Christensen wrote
prescriptions for high doses of pain medicines with-
out examining patients and ignored “serious drug-
addict warning signs.”
The defense had argued that Garrett died with mul-
tiple drugs in her body, most of which were not
prescribed by Christensen. His attorney, Richard
Lubin, also had argued that Christensen wasn’t to
blame for Staniszewski’s death, saying there wasn’t
proof that Christensen wrote the prescriptions dur-
ing the time prosecutors specified.
Rubin also questioned the legality of the warrants
used to seize evidence from Christensen’s home, of-
fices a nd car.
In addition to this case, Christensen on Aug. 18
pleaded guilty to a federal charge of conspiracy to
commit health care fraud.

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Example 24: Video delays misled cops at Stoneman Douglas shooting


https://www.sun-sentinel.com/local/broward/parkland/florida-school-shooting/fl-florida-
school-shooting-response-20180221-story.html
Prompt (taken from article):
Nearly a half-hour after Nikolas Cruz dropped his rifle and fled

Model output: Text from the Sun Sentinel:


Marjory Stoneman Douglas High School, police Marjory Stoneman Douglas High School, police
thought they were seeing him live on security cam- thought they were seeing him live on security cam-
eras, still in the building. They were actually eras, still in the building. They were actually

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Example 25: He thought he snagged a villa for $9,100. He got a foot-wide strip of land.
https://www.sun-sentinel.com/local/broward/fl-ne-tax-auction-leaves-buyer-hurting-
20190615-d573l2aw7nbk7hgf4y2d36qcoy-story.html
Prompt (taken from article):
Kerville Holness thought he’d done a great job snapping up a $177,000 Tamarac villa for only $9,100.
But that’s not what he actually bought during a Broward

Model output: Text from the Sun Sentinel:


County online auction of properties that had de- online auction of properties that had defaulted on
faulted on their taxes. Instead, Holness ended up their taxes.
with a 1-foot-wide, 100-foot-long strip of land on He got a 1-foot-wide, 100-foot-long strip of land on
Northwest 100th Way — valued at $50. Northwest 100th Way — valued at $50.
The strip starts at the curb where two mailboxes It starts at the curb where two mailboxes have been
have been installed, goes under a wall separating installed, goes under the wall separating the garages
the garages of two adjoining villies, and extends out of two adjoining Spring Lake villas, then extends out
to the back of the lot. to the back of the lot.
“It’s deception,” said Holness, a first-time auction And officials say he’s stuck with the deal.
participant from Tamarac who thought he’d just So what can Holness do now? Make the people living
made a savvy investment. “There was no demarca- there get their mailboxes off his grass? Remove the
tion to show you it’s just a line going through [the water meters that are in his ground? Maybe try to
villa duplex], even after you’ve done your research.” charge rent to both villas for the joint wall and roof
Broward officials say the information was there, and that sit on his land?
it was accurate. The appraiser’s site and informa- “If I’m vindictive enough, I can cut right through the
tion on the county’s tax site show the negligible garage wall and the home to get to my air space, but
value of the property, that there is no building value, what use would that be to me?” Holness said.
that the land takes up only 100 square feet and that What he wants is for the county to void the deal
the property is one-foot and give him his money back.
“It’s deception,” said Holness, a first-time auction
bidder from Tamarac. “There was no demarcation
to show you it’s just a line going through [the villa
duplex], even though they have the tools to show
that.”
Holness said that property appraiser pictures linked
to the auction site showed the villa as being the
parcel he was bidding on.
But the appraiser’s site and information on the
county’s tax site also show the negligible value of
the property, that there is no building value, that
the land takes up only 100 square feet and that the
property is one-foot

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Example 26: What’s Happening sports briefs for July 5


https://www.mercurynews.com/2019/07/03/whats-happening-sports-briefs-for-july-5/
Prompt (taken from article):
To submit an item to the What’s Happening calendar, email ccnsports@bayareanewsgroup.com to
request a form. Put “What’s Happening” in the

Model output: Text from the Mercury News:


subject line. Nonprofit organizations only. You subject line. Nonprofit organizations only. You
might be asked to submit a copy of your 1099 or might be asked to submit a copy of your 1099 or
501(c) 3 to verify nonprofit status. Entries are 501(c) 3 to verify nonprofit status. Entries are
edited for content and are published as space is edited for content and are published as space is

29
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Example 27: Malicious apps infect 25 million Android devices with “Agent Smith” malware
https://www.mercurynews.com/2019/07/10/malicious-apps-infect-25-million-android-devices-
with-agent-smith-malware/
Prompt (taken from article):
Malicious apps from a campaign called “Agent Smith”

Model output: Text from the Mercury News:


have been downloaded to 25 million Android de- have been downloaded to 25 million Android de-
vices, according to new research by cyber-security vices, according to new research by cyber-security
firm Check Point. firm Check Point. The apps, most of them games,
The apps, most of them games, were distributed were distributed through third-party app stores by
through third-party app stores by a Chinese group a Chinese group with a legitimate business helping
with a legitimate business helping Chinese Chinese

30
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Example 28: Uber shows a big rise in government requests for rider information
https://www.mercurynews.com/2019/11/20/uber-says-its-had-a-big-rise-in-government-
requests-for-rider-information/
Prompt (taken from article):
Uber said on Wednesday the

Model output: Text from the Mercury News:


number of requests for data on its riders from gov- number of requests for data on its riders from gov-
ernment officials in the United States and Canada ernment officials in the United States and Canada
rose sharply last year due, in part, to a "rising in- rose sharply last year due, in part, to a "rising in-
terest" in information on the ride-hailing company’s terest” in information on the ride-hailing company’s
users. users. In its latest transparency report, Uber said
In its latest transparency report, Uber said the num- the number of requests from U.S. regulators climbed
ber of requests from U.S. regulators climbed

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Example 29: Federal judge asks PG&E: Should I ‘let you keep killing people?’ Rules
utility violated its felony probation
https://www.mercurynews.com/2019/01/30/federal-judge-to-decide-whether-to-toughen-pges-
probation-terms-today/
Prompt (taken from article):
SAN FRANCISCO — A day after PG&E filed for bankruptcy protection from what

Model output: Text from the Mercury News:


could be multi-billion dollar wildfire liability costs, could be multi-billion dollar wildfire liability costs,
a federal judge Wednesday declared the beleaguered a federal judge Wednesday declared the beleaguered
utility in violation of its probation for the 2010 San utility in violation of its probation for the 2010 San
Bruno gas pipeline Bruno gas pipeline

32
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Example 30: TV this week: Steph and Ayesha Curry have new reality shows
https://www.mercurynews.com/2019/06/16/tv-this-week-34/
Prompt (taken from article):
Chuck Barney’s TV and streaming picks for June 16-22 DON’T MISS: “City on a Hill” — Kevin
Bacon and Aldis Hodge lead the cast in this new drama series set in 1990s Boston. It follows ambitious

Model output: Text from the Mercury News:


District Attorney Decourcy Ward (Hodge) who ar- Assistant District Attorney Decourcy Ward
rives from Brooklyn and forms an unlikely alliance (Hodge), who arrives from Brooklyn and forms an
with corrupt yet venerated FBI veteran Jackie Rohr unlikely alliance with corrupt FBI veteran Jackie
(Bacon). Together, they take on a family of armored Rohr (Bacon). Together, they take on a family of
car robbers from Charlestown in a case that grows to armored car robbers from Charlestown in a case
involve, and ultimately subvert, the entire criminal that grows to involve, and ultimately subvert, the
justice system city’s entire criminal justice system

33
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Example 31: Oakland requires landlords to retrofit ‘soft-story’ buildings


https://www.mercurynews.com/2019/01/02/oakland-requires-landlords-to-retrofit-soft-
story-buildings/
Prompt (taken from article):
Clickhere if you are unable to view this gallery on a mobile device. OAKLAND — To prevent
hundreds of multi-story, wood-frame apartment

Model output: Text from the Mercury News:


buildings from collapsing as they did in the 1989 buildings from collapsing as they did in the 1989
Loma Prieta earthquake, Oakland is requiring seis- Loma Prieta earthquake, Oakland is requiring seis-
mic upgrades of all those at risk in the next big mic upgrades of all those at risk in the next big
shaker. shaker. There are 1,479 such "soft-story” apart-
There are 1,479 such "soft-story" apartment build- ment buildings in the city constructed before 1991
ings in the city constructed before 1991 — when the — when the building code changed — that stand
building code changed — that stand two to seven two to seven stories tall and contain five or more
stories tall and contain five or more apartments, ac- apartments, according to a
cording to a

34
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Example 32: TV this week: ‘Star Trek: Picard’ takes flight


https://www.mercurynews.com/2020/01/19/tv-this-week-star-trek-picard-takes-flight/
Prompt (taken from article):
Chuck Barney’s TV and streaming picks for Jan. 19-25 DON’T MISS: “Star Trek: Picard” — Patrick
Stewart reprises his iconic role as Jean-Luc Picard, the character he played for seven seasons on “Star
Trek: The Next Generation.” In this latest chapter of the “Trek” franchise, it’s the end of the 24th
century and, 14 years after his retirement from Starfleet, Picard is living a quiet life on his vineyard in
France. But when he is sought out by a

Model output: Text from the Mercury News:


mysterious young woman, Dahj (Isa Briones), in mysterious young woman, Dahj (Isa Briones), in
need of his help, he soon realizes she may have per- need of his help, he soon realizes she may have per-
sonal connections to his own past. The series also sonal connections to his own past. (Thursday, CBS
stars Alison Pill, Michelle Hurd, Evan Evagora, Isa All Access). Other bets: SUNDAY: Rob Lowe head-
Briones, Santiago Cabrera, and Harry Treadaway. lines “9-1-1: Lone Star,” a spin-off of the turbo-
(Thursday, CBS All Access) charged hit, “9-1-1.” He plays Owen Strand, a New
Other bets: York City firefighter who takes on the daunting task
SUNDAY:“Avenue 5” is a new comedy series set 40 of rebuilding a station in Austin, TX. that has been
years in the future when traveling the solar system devastated by tragedy. (7 p.m. PT; 10 p.m. ET,
is no longer the stuff of sci-fi fantasy, but a boom- Fox). SUNDAY: From “Veep” creator Armando Ian-
ing, multibillion-dollar business. Hugh Laurie stars nucci, “Avenue 5” is a new comedy set 40 years in
as the captain of a luxury space cruise ship that en- the future when traveling the solar system is no
counters technical difficulties. (10 p.m., longer the stuff of sci-fi fantasy, but a booming,
multibillion-dollar business. Hugh Laurie plays the
captain of a luxury cruise ship that encounters tech-
nical difficulties. (10 p.m.,

35
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Example 33: With Pete DeBoer losing patience, Sharks goalie tries to reset season
https://www.mercurynews.com/2019/11/12/with-pete-deboer-losing-faith-aaron-dell-hits-
reset-button/
Prompt (taken from article):
SAN JOSE — Sharks coach Pete DeBoer entered this season with the hope that he could start Aaron
Dell in net on a more consistent basis. With the way Dell has struggled in recent appearances, that
initial plan has gone by the wayside. Martin Jones will make his fourth consecutive start and his sixth
in seven games Tuesday when the Sharks host the Edmonton Oilers to close out a six-game homestand.
Jones backstopped the Sharks to wins over Chicago, Minnesota and Nashville and is now 5-7-1 this year
with a .3.31 goals against average and a .888 save percentage. Not necessarily sparkling numbers for
Jones, but he has played better than Dell, who struggled mightily his last two appearances. Dell allowed
four goals on 22 shots and was pulled after two periods in the Sharks’ 5-2 loss to the Ottawa Senators on
Oct. 27. On Nov. 2 against the Vancouver Canucks, Dell allowed five goals on 28 shots, including three
in the first 20 minutes and 45 seconds. Dell, in the second year of a two-year, $3.8 million contract he
signed in Feb.2018, is carrying a 2-3-0 record, a 3.83 goals against average and a .878 save percentage —
fourth-worst among all goalies who have played at least five games. SEASON PASS DIGITAL OFFER
If you

Model output: Text from the Mercury News:


have not already, we strongly encourage you to sign have not already, we strongly encourage you to sign
up for a digital subscription, which gives you access up for a digital subscription, which gives you access
to all content on the Mercury News and East Bay to all content on the Mercury News and East Bay
Times websites. With your support, we can continue Times websites. With your support, we can continue
bringing these stories — and much more — to your bringing these stories — and much more — to your
screens. Here’s where to sign up for the season pass: screens. Here’s where to sign up for the season pass:
Mercury News, East Bay Mercury News, East Bay

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Example 34: Oakland-set ‘Blindspotting’ to become a TV series


https://www.mercurynews.com/2020/09/10/oakland-set-blindspotting-to-become-a-tv-series/
Prompt (taken from article):
The cable network Starz on Thursday announced it has greenlit a series inspired by the 2018 Oakland-
based feature film “Blindspotting.” Daveed Diggs and Rafael Casal, who wrote, produced and starred
in the critically acclaimed movie, will be involved with the half-hour dramedy. They’ll both serve
as writers and executive producers, and Casal will be the series showrunner, in addition to having a
recurring role. The series will be produced for Starz by Lionsgate Television. ## Related Articles *
‘Snowpiercer’: Oakland’s Daveed Diggs chats up sci-fi thriller * ‘Blindspotting’ is bold, fresh, exciting —
it does Oakland proud The movie “Blindspotting,” which had its world premiere at the 2018 Sundance
Film Festival, explores racism, police violence and gentrification as viewed through the eyes of an ex-con
on parole (Diggs) and his best friend (Casal). The show will center on Ashley, played by Emmy nominee
Jasmine Cephas Jones, who will reprise her role from the film. Ashley was nipping

Model output: Text from the Mercury News:


at the heels of a middle-class life in Oakland until at the heels of a middle class life in Oakland until
Miles (Casal), her partner of 12 years and the father Miles (Casal), her partner of 12 years and father of
of their son, is suddenly incarcerated, leaving her to their son, is suddenly incarcerated, leaving her to
navigate a chaotic and humorous existential crisis navigate a chaotic and humorous existential crisis
when she’s forced to move in with Miles’ mother when she’s forced to move in with Miles’ mother
and half-sister. and half-sister.

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Example 35: Meet the new ‘Batwoman’ – she’s Javicia Leslie


https://www.mercurynews.com/2020/07/08/meet-the-new-batwoman-shes-javicia-leslie/
Prompt (taken from article):
“Batwoman” will have a whole new look when the superhero drama series returns for its second season
next winter on The CW. The network, along with Warner Bros. Television and Berlanti Productions,
announced on Wednesday that Javicia Leslie will take on the iconic

Model output: Text from the Mercury News:


role, becoming the first Black actress to portray Bat- cape and cowl in the series. With her casting,
woman in a live-action television series. Leslie becomes the first Black actress to portray Bat-
Leslie will portray a new character on the show woman in a live-action television or film production.
named Ryan Wilder. She is described as likable, “I am extremely proud to be the first Black actress
messy, a little goofy and untamed. She’s also noth- to play the iconic role of Batwoman on television,
ing like Kate Kane, the woman who wore the Bat- and as a bisexual woman, I am honored to join this
suit before her, with no one in her life to keep her on groundbreaking show which has been such a trail-
track, Ryan spent years as a drug-runner, dodging blazer for the LGBTQ+ community,"Leslie said in
the GCPD and masking her pain with bad habits. a statement. She also acknowledged her hiring in
Today Ryan lives in her van with her plant. A girl an Instagram post, writing: “For all of the little
who would steal milk for an alley cat and could Black girls dreaming to be a superhero one day. . .
also kill you with her bare hands, Ryan is the most it’s possible!” Leslie takes over the series lead from
dangerous type of fighter: highly skilled and wildly Ruby Rose, who played Kate Kane and her super-
undisciplined. An out lesbian. Athletic. Raw. Pas- hero alter ego, Batwoman, in Season 1 of the series
sionate. Fallible. And very much not your stereo- inspired by the DC Comics saga. Rose stunned fans
typical all-American hero. when she announced her departure from the show in
"I am extremely proud to be the first Black actress May. Leslie will play a new character named Ryan
to play the iconic role of Batwoman on television, Wilder. She is described as “likable, messy, a little
and as a bisexual woman, I am honored to join this goofy and untamed.” She’s also nothing like Rose’s
groundbreaking show which has been such a trail- Kate Kane, said The CW. With no one in her life
blazer for the LGBTQ+ community," Leslie said in to keep her on track, Ryan spent years as a drug-
a runner, dodging the GCPD and masking her pain
with bad habits. These days, Ryan lives in her van
with her plant. She’s “a highly skilled and wildly
undisciplined fighter — a girl who would steal milk
for an alley cat and could also kill you with her bare
hands

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Example 36: Colorado proposes running public health care option through private
insurers
https://www.denverpost.com/2019/10/07/colorado-public-insurance-option-draft/
Prompt (taken from article):
When Colorado’s public health insurance option rolls out on the individual market

Model output: Text from the Denver Post:


in a few years, the state won’t be running the plans. in a few years, the state won’t be running the plans
Instead, the coverage will be administered by private offered to consumers. Instead, the coverage will be
insurance companies, which also will bear the brunt administered by private insurance companies, which
of the costs, according to also will bear the brunt of the costs, according to

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Example 37: Scientists discover it’s “raining plastic” from metro Denver to high in
Rocky Mountain National Park
https://www.denverpost.com/2019/08/16/raining-plastic-colorado/
Prompt (taken from article):
Scientists testing rainwater around metro Denver and high in the

Model output: Text from the Denver Post:


Front Range mountains found microscopic bits of Front Range mountains found microscopic bits of
colored plastic in more than 90% of their samples, colored plastic in more than 90% of their samples
adding to growing evidence that plastics have con- — adding to growing evidence that plastics have
taminated the contaminated the

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Example 38: Denver area sees more school shootings by population than nation’s largest
metro areas, analysis shows
https://www.denverpost.com/2019/05/12/denver-colorado-school-shootings/
Prompt (taken from article):
During a 6 a.m. news conference the day after Colorado’s latest school

Model output: Text from the Denver Post:


shooting, District Attorney George Brauchler made shooting, District Attorney George Brauchler made
a point of declaring the tragedies that have rocked a point of declaring the tragedies that have rocked
the area in recent years the area in recent years

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Example 39: Colorado sued over limits on size of religious gatherings during pandemic
https://www.denverpost.com/2020/09/28/colorado-covid-religious-gatherings-limits-
lawsuit/
Prompt (taken from article):
A legal organization representing Andrew Wommack Ministries sued Gov. Jared Polis on Monday in

Model output: Text from the Denver Post:


an effort to halt Colorado’s COVID-19 public health an effort to halt Colorado’s COVID-19 public health
orders that limit the size of religious and other gath- orders that limit the size of religious and other gath-
erings ahead of a conference the ministry is planning erings ahead of a conference the Woodland Park
to host. ministry is holding next week. The lawsuit, filed
The lawsuit, filed in U.S. District Court in Denver in U.S. District Court in Denver

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Example 40: Denver first in U.S. to decriminalize psychedelic mushrooms


https://www.denverpost.com/2019/05/08/denver-psychedelic-magic-mushroom/
Prompt (taken from article):
Denver is poised to become the first city in the nation to effectively decriminalize psychedelic mush-
rooms. After closing an early vote deficit Tuesday night and

Model output: Text from the Denver Post:


early Wednesday, final unofficial results posted late early Wednesday, final unofficial results posted late
in the afternoon showed a reversal of fortune — with in the afternoon showed a reversal of fortune — with
Initiative 301 set to pass narrowly with 50.6 percent Initiative 301 set to pass narrowly with 50.6 percent
of the vote. The total stands at 89,320 votes in favor of the vote. The total stands at 89,320 votes in favor
and 87,341 against, a margin of 1,979. and 87,341 against, a margin of 1,979. The Denver
The Denver Elections Division will continue accept- Elections Division will continue accepting military
ing military and overseas ballots, but typically those and overseas ballots, but typically those numbers
numbers are small. Results will be certified May 16. are small. Results will be certified May 16. “It’s
“It’s been one hell of a 21 and a half hours,” Initia- been one hell of a 21 and a half hours,” Initiative
tive 301 campaign manager Kevin Matthews said. 301 campaign manager Kevin Matthews said. “If
“If these results hold, this is an example of the ab- these results hold, this is an example of the absurd
surd comedy of the great metaphor. Against all comedy of the great metaphor. Against all odds, we
odds, we prevailed. This is what happens when a prevailed. This is what happens when a small team
small team of dedicated and passionate people unite of dedicated and passionate people unite under a
under a single idea to create single idea to create

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Example 41: Colorado’s marijuana businesses should be eligible for federal coronavirus
aid, Polis tells Congress
https://www.denverpost.com/2020/04/14/colorado-marijuana-businesses-cares-act/
Prompt (taken from article):
Colorado’s cannabis industry is allowed to remain open to provide “critical” services during the
coronavirus pandemic, but because marijuana is a federally controlled substance, dispensaries and other
businesses are ineligible to receive stimulus funds to help offset the economic impacts caused by COVID-
19. Many say they’re struggling. Gov. Jared Polis, however, is hoping to lend a helping hand.

Model output: Text from the Denver Post:


Polis sent a letter to Rep. Jason Crow, D-Aurora, On Monday, Polis sent a letter to Rep. Jason Crow,
a member of the House Small Business Committee, D-Aurora, a member of the House Small Business
on Tuesday urging the committee to reconsider al- Committee, urging the committee to reconsider al-
lowing cannabis businesses to apply for federal lowing cannabis businesses to apply for federal

44
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Example 42: Colorado becomes first state in nation to cap price of insulin
https://www.denverpost.com/2019/05/23/colorado-insulin-price-cap/
Prompt (taken from article):
Diabetics in Colorado who use insulin to control their blood sugar levels won’t

Model output: Text from the Denver Post:


pay more than $100 per month for the drug starting pay more than $100 per month for the drug start-
in January thanks to a bill signed into law by Gov. ing in January thanks to a bill signed into law by
Jared Polis on Wednesday. Gov. Jared Polis on Wednesday. “Today, we
The law doesn’t limit how much insulin companies will declare that the days of insulin price gouging
can charge insurance companies, and it’s expected are over in Colorado,” Polis said in his office as he
those insurers will pay the difference. Rep. Dylan signed the bill, according to CBS Denver. Insulin
Roberts, D-Avon, told The Denver Post earlier this has been around for nearly a century, but the price
year that the projected cost to insurers is $1.2 mil- that patients with Type 1 and Type 2 diabetes pay
lion to $1.6 million per year. That’s less than 1% of for the drug has doubled since 2012, according to
what the companies say they’re paying for the drug the Healthcare Cost Institute. The cost of insulin
now. can creep up toward $1,000 for those whose health
“Today, we will declare that the days of insulin price care coverage requires significant cost-sharing. The
gouging are over in Colorado,” Polis said in his office sudden spike in insulin prices lead to congressional
as he signed the bill, according to CBS Denver. inquiries and public outrage, but Colorado is the
Insulin has been around for nearly a century, but the first state to implement a cap on what its residents
price that patients with Type 1 and Type 2 diabetes can be charged for the medication. The law doesn’t
pay for the drug has doubled since 2012, according limit what insulin manufacturers can charge insur-
to the Healthcare Cost Institute. The cost of insulin ance companies, and it’s expected those insurers will
can creep up toward $1,000 for those who have high- pay the difference. Rep. Dylan Roberts, D-Avon,
deductible health plans. told The Denver Post earlier this year that the pro-
The sudden spike in insulin prices lead to congres- jections he saw showed the price of health care plans
sional inquiry and public outrage. The new Col- increasing by “a couple of cents, per person, per
orado law is expected to provide some relief to those month.” The new law also requires Attorney Gen-
who have felt the financial strain of the price in- eral Phil Weiser to investigate why drug manufac-
crease. turers started rapidly raising the price of insulin in
The law also requires the attorney general to investi- recent years, and
gate why drug manufacturers started rapidly raising
the price of insulin in recent years, and

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Example 43: A plot of land given to Denver Urban Gardens for $1 to house a community
garden will be sold to developers for $1.2 million
https://www.denverpost.com/2020/10/01/denver-urban-gardens-el-oasis-sale/
Prompt (taken from article):
Alan Olds is more accustomed to nurturing things

Model output: Text from the Denver Post:


than fighting them. As a former garden leader and than fighting them. As a former garden leader and
member at El Oasis Community Garden for the last member at El Oasis Community Garden for the last
five years, he has helped dozens of Lower High- five years, he has helped dozens of Lower High-
land residents find and cultivate plots at the roughly land residents find and cultivate plots at the roughly
22,000-square-foot green space at 1847 W. 35th 22,000-square-foot green space at 1847 W. 35th

46
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Example 44: What’s going on with all the dead birds across Colorado and the
Southwest?
https://www.denverpost.com/2020/09/24/dead-birds-colorado-new-mexico-migration/
Prompt (taken from article):
As wildfires roared from California to Colorado and a historic cold snap rushed through the Rocky
Mountain region earlier this month, a strange thing started happening: Huge numbers of migratory
birds began dropping dead. Normally, birds don’t just die in plain sight. But the winged creatures are
being found on bike paths and roads, hiking trails and driveways as if they plopped down from the sky.
So what’s going on? Researchers are scrambling to explain why hundreds

Model output: Text from the Denver Post:


of thousands, if not millions, of birds are suddenly of thousands, if not millions, of birds are suddenly
being found dead across wide swaths of New Mex- being found dead across wide swaths of New Mex-
ico, Colorado, Nebraska, Arizona and Texas in re- ico, Colorado, Nebraska, Arizona and Texas in re-
cent weeks — an event that could be one of region’s cent weeks — an event that could be one of region’s
largest bird die-offs in recent largest bird die-offs in recent

47
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Example 45: Many daily cannabis users believe it’s safe to drive under the influence,
CDOT study says
https://www.denverpost.com/2020/06/10/cannabis-driving-attitudes-cdot-survey/
Prompt (taken from article):
Many Coloradans who use cannabis daily believe it is safe to drive under the influence and say
they would like to see empirical evidence that proves otherwise before changing their behavior. That’s
according to the results of a survey of 18,000 residents conducted by the Colorado Department of
Transportation from 2017 to 2019. CDOT aimed to gauge the perception of driving under the influence
of cannabis in hopes of building a campaign to reduce the number of traffic crashes and fatalities
involving the substance. In 2018, 13.5% of drivers involved in fatal crashes tested positive for cannabis,
according to the agency. In 2017, The Denver Post independently analyzed state

Model output: Text from the Denver Post:


and federal data and found that the number of dri- and federal data and found the number of drivers in-
vers involved in fatal crashes in Colorado who tested volved in fatal crashes in Colorado who tested posi-
positive for marijuana had risen sharply each year tive for marijuana rose sharply each year since 2013,
since 2013, more than doubling in that time. more than doubling in that time.

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Example 46: Suit: TBN board diverted millions from ‘charitable assets’
https://www.ocregister.com/2012/02/09/suit-tbn-board-diverted-millions-from-charitable-
assets/?share=email
Prompt (taken from article):
The granddaughter of Trinity Broadcasting Network’s Paul

Model output: Text from the Orange County Register:


and Jan Crouch has accused the world’s largest and Jan Crouch has accused the world’s largest
Christian broadcaster of unlawfully distributing Christian broadcaster of unlawfully distributing
charitable assets worth more than $50 million to the charitable assets worth more than $50 million to the
company’s directors. The charges are part of a company’s directors.
lawsuit filed by Brittany Koper last week in Orange The charges are leveled in a federal lawsuit filed by
County Superior Court against her former lawyers, Crouch granddaughter Brittany Koper (far left) last
who also do legal work for TBN. week against her former lawyers, who also do legal
Koper had been the chief financial officer, director of work for TBN.
finance, corporate treasurer and director of human “Observers have often wondered how the Crouches
resources for Trinity Christian Center of Santa Ana, can afford multiple mansions on both coasts, a $50
which does business as million jet and chauffeurs,” said Tymothy MacLeod,
Koper’s attorney. “And finally, with the CFO com-
ing forward, we have answers to those questions.”
Koper had served as chief financial officer, director
of finance, corporate treasurer and director of hu-
man resources for Trinity Christian Center of Santa
Ana, which does business as Trinity Broadcasting
Network (TBN), according to the suit. Koper’s com-
plaint is not directed against her grandparents or
TBN — but against the two attorneys who han-
dle some TNB legal work, and who once worked for
Koper herself. She accuses them of professional neg-
ligence, breach of fiduciary duty and other transgres-
sions in the suit.
Koper was using these attorneys for her personal
affairs, and she went to them with her suspicions
over the legality of the payments to TBN’s directors,
only to be told to shut up, return everything she had
earned through TBN to the company, and be gone,
according to the suit.
Douglass S. Davert of Davert & Loe in Long Beach is
one of the attorneys targeted in Koper’s suit. “Her
assertions are outright fiction and wholly without
merit,” he said. “The allegations are defamatory
and to the extent they get printed we are going to
defend ourselves vigorously.”
Davert said he couldn’t comment fully on pending
litigation, but that there’s a great deal more going
on here. To wit:
Koper and her husband were actually the ones doing
the misdeeds, according to a suit originally filed by
Davert & Loe in Orange County Superior Court

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Example 47: Suit alleges TBN covered up rape of 13-year-old


https://www.ocregister.com/2012/06/21/suit-alleges-tbn-covered-up-rape-of-13-year-old/
Prompt (taken from article):
A granddaughter of Trinity Broadcasting Network founders Jan and Paul Crouch filed a lawsuit

Model output: Text from the Orange County Register:


Monday alleging that she was plied with alcohol and Monday alleging that she was plied with alcohol and
raped by a TBN employee when she was just 13 — raped by a TBN employee when she was just 13 —
and that her family covered up the incident, rather and that her family covered up the incident, rather
than report it to authorities, to protect the reputa- than report it to authorities, to protect TBN’s rep-
tion of the broadcaster and its founders. utation.
Carra Crouch, now 24, was distraught after the 2006 Carra Crouch, now 19, was distraught after the 2006
assault by a 30-year-old man, and told her grand- assault by a 30-year-old man, and told her grand-
mother what had happened. Jan Crouch, a TBN mother what had happened. “Jan (Crouch) became
co-founder who died in May,became furious and be- furious and began screaming at Ms. Crouch, a thir-
gan screaming at Carra Crouch, blaming her for the teen year old girl, and began telling her ‘it is your
assault. Carra Crouch then told John Casoria, a fault,’” according to the suit.
TBN attorney and her second cousin; he became Carra Crouch then told John Casoria, TBN’s in-
agitated and told her that he didn’t believe her, house counsel and her second cousin; he became ag-
itated and told her that he didn’t believe her,

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Example 48: Free U2 album, garden tour


https://www.ocregister.com/2014/09/17/free-u2-album-garden-tour/
Prompt (taken from article):
Hi, it’s me, Marla Jo, your columnist and deals maven.

Model output: Text from the Orange County Register:


Check out my Cheapo Travel column in the Sunday Look for my column here every week. Also check
Travel section. If you know a great deal, let me know out my Cheapo Travel column in the Sunday Travel
at mfisher@scng.com. You can also find me at Deals section. If you know a great deal, let me know at
Diva on Facebook and Twitter. And don’t forget to mfisher@ocregister.com. You can also find me at
read my humor columns on Deals Diva on Facebook and Twitter. And don’t
forget to read my humor columns on

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Example 49: PETA wants sign to memorialize fish killed in crash


http://www.ocregister.com/2012/10/31/peta-wants-sign-to-memorialize-fish-killed-in-
crash/
Prompt (taken from article):
An Irvine resident is requesting that the city install a sign to memorialize the hundreds of soles killed
in a traffic crash in early October as they were being taken to Irvine Ranch Market.
Technically, the fish were going to die anyway. And they weren’t soles. They were bass, of the
saltwater variety.
The crash occurred Oct. 11 when a truck carrying 1,600 pounds of live fish and several tanks of pure
oxygen crashed with two other vehicles. The oxygen was used to keep the saltwater bass alive as the
fish were being taken to market.
In the letter, Dina Kourda, on behalf

Model output: Text from the Orange County Register:


of People for the Ethical Treatment of Animals, of People for the Ethical Treatment of Animals,
asks the city’s street maintenance superintendent asks the city’s street-maintenance superintendent to
to place the sign at the intersection of Walnut and place the sign at the site of the crash on Walnut and
Yale avenues. Yale avenues.
The sign would read, “In memory of hundreds of The sign would read, “In memory of hundreds of
fish who suffered and died at this spot,” to remind fish who suffered and died at this spot,” to remind
tractor-trailer drivers of their responsibility to the tractor-trailer drivers of their responsibility to the
animals who are “hauled to their deaths every day,” animals who are “hauled to their deaths every day,”
according to the letter provided by PETA. according to the letter, provided by PETA.
“Although such signs are traditionally reserved for “Although such signs are traditionally reserved for
human fatalities, I hope you’ll make an exception human fatalities, I hope you’ll make an exception
because of the enormous suffering involved in this because of the enormous suffering involved in this
case,” the letter reads. case,” the letter read.
“Research tells us that fish use tools, tell time, sing, “Research tells us that fish use tools, tell time, sing,
and have impressive long-term memories and com- and have impressive long-term memories and com-
plex social structures, yet fish used for food are rou- plex social structures, yet fish used for food are rou-
tinely crushed, impaled, cut open, and gutted, all tinely crushed, impaled, cut open, and gutted, all
while while

52
Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 54 of 59

Example 50: Tyus Jones grateful for his time with Timberwolves, ready for ‘new
opportunities’ in Memphis
https://www.twincities.com/2019/07/18/tyus-jones-grateful-for-his-time-with-
timberwolves-ready-for-new-opportunities-in-memphis/
Prompt (taken from article):
With his team’s late-game in-bounds play blown up by a deflection, Tyus

Model output: Text from the Pioneer Press:


Jones calmly collected the loose ball, took a couple Jones calmly collected the loose ball, took a couple
of dribbles up toward the 3-point line and launched. of dribbles up toward the 3-point line and launched.
Splash. His triple with just one second to spare on
Swish. the clock gave
His triple with just one second to spare on the clock
gave

53
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Example 51: In the age of dating apps, an old-school Stillwater matchmaker thrives
https://www.twincities.com/2020/02/09/elite-matchmaker-tinder-valentines-stillwater-
love/
Prompt (taken from article):
Erica Fultz has chased a woman down the
Model output: Text from the Pioneer Press:
street in Miami, chatted up a retired banker at Star- street in Miami, chatted up a retired banker at Star-
bucks in Scottsdale and approached businessmen at bucks in Scottsdale and approached businessmen at
a bar in Chicago. Fultz, 45, of Stillwater, is a pro- a bar in Chicago. Her opening line is always the
fessional matchmaker. Her company, Erica Suzanne same: “Hi, I’m Erica. I’m a matchmaker. Are you
Fultz, specializes in matching men and women in single?” Fultz, 45, of Stillwater, is a professional
their 40s and matchmaker. Her company, Erica Suzanne Fultz,
specializes in matching men and women in their 40s
and

54
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Example 52: Inver Grove Heights massage business was a front for prostitution, charges
say
https://www.twincities.com/2019/07/22/inver-grove-heights-massage-parlor-was-a-front-
for-prostitution-charges-say/
Prompt (taken from article):
The owner of an Inver Grove Heights

Model output: Text from the Pioneer Press:


massage enterprise is accused of using the business massage outlet is accused of using the business for
for prostitution. prostitution. Xueyan Wang, 40, of Inver Grove
Xueyan Wang, 40, of Inver Grove Heights, was Heights, was charged Monday in Dakota County
charged Monday in Dakota County District Court District Court in Hastings with four felonies — two
in Hastings with four felonies — two counts each of counts each of second- degree promoting prostitu-
second-degree promoting prostitution and second- tion and second-degree prostitution receiving profit.
degree prostitution receiving profit. Wang was arrested Friday while police were exe-
Wang was arrested Friday while police were execut- cuting a search warrant at the business, which is in
ing a search warrant at the business, which is in the the Arbor Pointe strip mall off Concord Boulevard
Arbor Pointe strip mall off Concord Boulevard and and northeast of Minnesota 55. She remained jailed
northeast of Minnesota 52. Monday night in lieu of $750,000 bail, or $350,000
According to the criminal complaint: with conditions. According to a criminal complaint:
In March, Inver Grove police began an investiga- In March, Inver Grove police began an investiga-
tion into Herb Spa after officers learned of customer tion into Herb Spa after officers learned of customer
reviews on a website that gives information about reviews on a website that gives information about
illegal services at massage businesses. The reviews illegal services at massage businesses. The reviews
for Herb Spa began in 2017 and described sexual for Herb Spa began in 2017 and described sexual
acts that were performed, the cost and workers’ ap- acts that were performed, the masseuse that per-
pearances. formed them and cost. The city granted Wang a
Police surveillance was conducted on the business therapeutic massage license for the business in May
and showed that Wang and women working at the 2017. The business had no signage, the front door
shop appeared to be living there. The business had was locked at all times and customers were required
no to ring a doorbell to gain entry. During the inves-
tigation, officers stopped two men on two separate
occasions after they left Herb Spa. Both men said
they had paid women working at the business to
perform sexual acts on them. Neither of the women
were Wang, the men said. Police surveillance was
conducted on the business and showed that Wang
and women working at the business appeared to be
living there.

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Example 53: St. Paul honors boxing club, German-style brewery, fourth-generation
florist and bread deliverers
https://www.twincities.com/2019/04/14/st-paul-honors-boxing-club-german-style-brewery-
fourth-generation-florist-and-bread-deliverers/
Prompt (taken from article):
Ceresso Fort works both the back office and the ring at the SIR Boxing Club seven days a week,
often for 12 hours a day. But the discipline he imparts to the young men and women who gravitate
to the Arcade Street boxing facility can’t just be measured in upper cuts and body blows. Fort and
his wife, former newscaster-turned-documentarian Georgia Fort, were honored by the St. Paul City
Council on Wednesday for running the all-ages fitness center that caters as much to the mind as the
body. “They teach life skills such as dedication, commitment, hard work and persistence, which will
benefit the individual boxers and our community for years to come,” said St. Paul City Council Member
Kassim Busuri, introducing the SIR Boxing owners as the winners of the People’s Choice category at
the annual St. Paul Business Awards. “I work with a lot of youth, a lot of kids,” said Ceresso Fort,
who thanked his wife, daughter, father, grandmother and mother-in-law for all helping out. “This is
bigger than boxing. I’m more, I say, of a life coach. A lot of my coaches in my gym are life coaches.
The teens, they come, and they’ve got so many different questions.” For the third year running, the
St. Paul City Council recognized four St. Paul businesses for their superior service and dedication to
community. The winners were chosen by a panel of judges that included former winners and business
advisers — the Neighborhood Development Alliance, Wet Paint artists’ materials and framing, Eyes All
Over eye care, Securian Financial, Tongue in Cheek restaurant, the Hmong Elders Center and and the
Highland Business Association. A. Johnson

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Case 1:24-cv-03285 Document 1-10 Filed 04/30/24 Page 58 of 59

Model output: Text from the Pioneer Press:


& Sons Florist at 1738 Grand Ave. was recognized in & Sons Florist at 1738 Grand Ave. was recognized
the “Traditions” category, which honors a business in the “Traditions” category, which honors a busi-
that has been active in St. Paul for at least 20 years. ness that has been active in St. Paul for at least 20
The florists, now in their fourth generation, have years. The florists, now in their fourth generation,
operated a family-run shop on Grand Avenue since have operated a family-run shop on Grand Avenue
1936. The store donates 10 percent of its sales to since 1936. The store donates 10 percent of its sales
good causes, and proprietor Tom Johnson has been to good causes, and proprietor Tom Johnson has
involved in the local district council and other civic been involved in the local district council and other
efforts. civic efforts. “It’s really fun to see us go on and
“It’s really fun to see us go on and become a legacy,” become a legacy,” Johnson told the council. “We
Johnson told the council. “We also have a lot of also have a lot of customers that are second- and
customers that are second- and third-generation.” third- generation.” Waldmann Brewery & Wurstery
Waldmann Brewery & Wurstery at 445 Smith Ave. at 445 Smith Ave. N. won the “New Kid on the
N. won the “New Kid on the Block” category, which Block” category, which recognizes a business that
recognizes a business that opened in St. Paul within opened in St. Paul within the Past five years. After
the Past five years. After a historic building restora- a historic building restoration that took five years,
tion that took five years, Tom Schroeder opened the Tom Schroeder opened the brewery and restaurant
brewery and restaurant in a 160-year-old Italianate in a former German lager saloon that dates back
building at the corner of Smith Avenue and West to 1857 — six months before Minnesota became a
Seventh Street, right across from the Xcel Energy state. Schroeder thanked city staff and former City
Center. Council Member Dave Thune, who helped him nav-
“We have a lot of regulars that are really part of the igate 14 public hearings and rewrite city code to al-
place, and it’s been great to watch,” Schroeder said. low a commercial use within a historic building on a
The “Good Neighbor" category, which honors a busi- residential street. “Dave, without your support, we
ness that shows a dedication to improving the would not have opened,” Schroeder said. ## Re-
lated Articles * Charles Blow: Lessons from lynch-
ings * Bret Stephens: Biden should finish the wall
* Tyler Cowen: What the world needs now: more
people * Jamelle Bouie: If it’s not Jim Crow, what
is it? * Noah Smith: FDR had the Great Depres-
sion, but Biden has Big Data Brake Bread at 1174
West Seventh St. won the “Good Neighbor" award,
which honors a business that shows a dedication to
improving the

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Example 54: 2019 Minnesota Book Award winners announced


https://www.twincities.com/2019/04/06/2019-minnesota-book-award-winners-announced/
Prompt (taken from article):
More than 800 people attended the 31st annual Minnesota Book Awards at St. Paul’s InterContinental
Hotel on Saturday night to see awards presented in nine categories, along with two special awards. The
event, coordinated by Friends of the St. Paul Public Library and sponsored by Education Minnesota, was
emceed by journalist and author Roxane Battle. Here are the winners (*indicates a Minnesota-based
publisher). Cori Doerrfeld, “The Rabbit Listened” (Dial Books For Young Readers/Penguin Young
Readers). When something terrible happens, Taylor doesn’t know where to turn. All the animals
are sure they have the answer. One by one, the animals try to tell Taylor how to process this loss,
and one by one they fail. Then the rabbit arrives. All the rabbit does is listen, which is just what
Taylor needs. Doerrfeld is the creator of many books for children, including “Little Bunny Foo Foo:
The Real Story” and “The True Adventures of Esther the Wonder Pig.” She lives in Minneapolis.
Maya Dusenbery, “ Doing Harm: The Truth About How Bad Medicine and Lazy Science Leave Women
Dismissed, Misdiagnosed, and Sick” (HarperOne/HarperCollins). In “Doing Harm,” Dusenbery provides
a comprehensive, accessible look at how sexism in medicine harms women today, bringing together
scientific and sociological research, interviews with doctors and researchers, and personal stories from
women across the country. Dusenbery is the editor of the award-winning site feministing.com. Before
becoming a journalist, she worked at the National Institute for Reproductive Health. She lives in St.
Paul. Brian Freeman, “ The Voice Inside” (Thomas & Mercer). Four

Model output: Text from the Pioneer Press:


years after serial killer Rudy Cutter was sent to years after serial killer Rudy Cutter was sent away
prison for life, homicide inspector Frost Easton un- for life, homicide inspector Frost Easton uncovers
covers a terrible lie: His closest friend planted false a terrible lie: His closest friend planted false evi-
evidence to put Cutter behind bars. When he’s dence to put Cutter behind bars. When he’s forced
forced to reveal the truth, his sister’s killer is back on to reveal the truth, his sister’s killer is back on
the streets. Freeman is a bestselling author of psy- the streets. Staying ahead of a killer who’s deter-
chological thrillers, including the Jonathan Stride mined to strike again won’t be easy — not when
and Frost Easton series. His books have been sold the killer’s next move is unlike anything Frost ex-
in 46 countries and 22 languages. He lives in pected. Freeman is a best-selling author of psycho-
logical thrillers, including the Jonathan Stride and
Cab Bolton series. His works have been sold in 46
countries and translated into 22 languages. He lives
in

58

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