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Page 1 APPLICATION FOR APPROVAL OF COMPLEX LITIGATION DESIGNATION (TRANSACTION ID # 210065985) FILED BY DEFENDANT ALTMAN, SAMUEL BROCKMAN, GREGORY OPENAI, INC. OPENAI, LP OPENAI, LLC OPENAI GP, LLC OPENAI OPCO, LLC OPENAI GLOBAL LLC OAI CORPORATION, LLC OPENAI HOLDINGS LLC: 1
2
3
4
5
6
7
8
9
10
11
12
13
14
JORDAN ETH (CA SBN 121617)
JEth@mofo.com
RAGESH K. TANGRI (CA SBN 159477)
RTangri@mofo.com
DAVID J. WIENER (CA SBN 291659)
DWiener@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105
Telephone: (415) 268-7126
Facsimile: (415) 268-7522
COUNTY OF SAN FRANCISCO
ELON MUSK, an individual,
19
Plaintiff,
v.
26
SAMUEL ALTMAN, an individual, GREGORY
BROCKMAN, an individual, OPENAI, INC., a
corporation, OPENAI, L.P., a limited partnership,
OPENAI, L.L.C., a limited liability company,
OPENAI GP, L.L.C., a limited liability company,
OPENAI OPCO, LLC, a limited liability
company, OPENAI GLOBAL, LLC, a limited
liability company, OAI CORPORATION, LLC,
a limited liability company, OPENAI
HOLDINGS, LLC, a limited liability company,
and DOES 1 through 100, inclusive,
27
Defendants.
22
23
24
25
BY: AUSTIN LAM
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
17
21
03/06/2024
Clerk of the Court
Attorneys for Defendants
SAMUEL ALTMAN, GREGORY BROCKMAN,
OPENAI, INC., OPENAI, LP, OPENAI, LLC,
OPENAI GP, LLC, OPENAI OPCO, LLC, OPENAI
GLOBAL LLC, OAI CORPORATION, LLC, AND
OPENAI HOLDINGS LLC
16
20
FILED
Superior Court of California,
County of San Francisco
William Savitt (pro hac vice application forthcoming)
Sarah K. Eddy (pro hac vice application forthcoming)
Randall W. Jackson (pro hac vice application forthcoming)
WACHTELL, LIPTON, ROSEN & KATZ
51 West 52nd Street
New York, NY 10019
Telephone: (212) 403-1000
Facsimile: (212) 403-2000
15
18
ELECTRONICALLY
Case No.: CGC-24-612746
DEFENDANTS’ APPLICATION
FOR COMPLEX DESIGNATION
Date Action Filed:
Trial Date:
28
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
February 29, 2024
None SetPage 2 1
Defendants Samuel Altman, Gregory Brockman, OpenAI, Inc., and affiliated OpenAI
2
entities (collectively, “Defendants”) respectfully submit that this action warrants dedicated judicial
3
management and for that reason request an order designating the action “complex” pursuant to
4
California Rule of Court 3.400.
5
I.
INTRODUCTION AND BACKGROUND
6
Though an early supporter and board member of OpenAI, Inc. (together with its affiliates,
7
“OpenAI”), Plaintiff Elon Musk quit the company years ago and started his own for-profit AI
8
business. Were this case to proceed to discovery, the evidence would show that Musk supported a
9
for-profit structure for OpenAI, to be controlled by Musk himself, and dropped the project when
10
his wishes were not followed. Seeing the remarkable technological advances OpenAI has achieved,
11
Musk now wants that success for himself. So he brings this action accusing Defendants of
12
breaching a contract that never existed and duties Musk was never owed, demanding relief
13
calculated to benefit a competitor to OpenAI. Musk purports to bring this suit for humanity, Compl.
14
¶ 33, when the truth—evident even from the face of Musk’s contradictory pleading—is that he
15
brings it to advance his own commercial interests.
16
According to the complaint, all Defendants entered a “Founding Agreement” with Musk,
17
Compl. ¶ 24, promising him OpenAI would never operate for profit and would release all its AI
18
publicly—promises all Defendants purportedly breached by, among other things, licensing
19
OpenAI’s core GPT-4 technology. Id. ¶¶ 123-25. Musk further claims that all Defendants breached
20
fiduciary duties and engaged in unfair business practices by using early contributions Musk made
21
to OpenAI for purposes supposedly inconsistent with this alleged “Founding Agreement.”
22
Id. ¶¶ 133-44.
23
There is no Founding Agreement, or any agreement at all with Musk, as the complaint itself
24
makes clear. The Founding Agreement is instead a fiction Musk has conjured to lay unearned claim
25
to the fruits of an enterprise he initially supported, then abandoned, then watched succeed without
26
him. The documents Musk cites as purportedly memorializing a binding contract with him—
27
OpenAI’s certificate of incorporation and a few emails—on their face show no promises to Musk.
28
2
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746Page 3 1
See id. ¶¶ 23-28, 50-57, 124. The pleading nowhere alleges that Musk’s early donations were
2
conditioned on Defendants following a specific business plan, nor could it.
3
The relief Musk seeks is as extraordinary as his claims are contrived. Musk requests an
4
order compelling OpenAI to reorganize and distribute its technology in accordance with the terms
5
of his fictitious contract. And he wants a “judicial determination”—with an accompanying
6
mandatory injunction—that certain OpenAI technology “constitutes Artificial General
7
Intelligence,” i.e., “having intelligence for a wide variety of tasks like a human” (when it does not).
8
Compl. at p. 34; id. ¶ 17.
9
Frivolous though Musk’s legal claims are, “exceptional judicial management” is warranted
10
to ensure that this case is litigated efficiently, expeditiously, and fairly. See Cal. R. Ct. 3.400(a).
11
Pretrial motion practice will be intensive; the facts Musk purports to put at issue are complicated,
12
highly technical, and span nearly a decade; and the relief Musk seeks is extraordinary and if granted
13
would require ongoing supervision. These factors weigh decisively in favor of a “complex”
14
designation and assignment for all purposes to this Court’s Complex Civil Litigation Department
15
pursuant to California Rule of Court 3.400.
16
II.
17
Under the California Rules of Court, a “complex case” is one that “requires exceptional
18
judicial management to avoid placing unnecessary burdens on the court or the litigants and to
19
expedite the case, keep costs reasonable, and promote effective decision making by the court, the
20
parties, and counsel.” Cal. R. Ct. 3.400(a).
21
22
23
24
DISCUSSION
In assessing whether a case merits “complex” treatment, courts consider a non-exhaustive
list of factors, including whether it will likely involve:
(1) Numerous pretrial motions raising difficult or novel legal issues that will be
time-consuming to resolve;
25
(2) Management of a large number of witnesses or a substantial amount of documentary
evidence;
26
(3) Management of a large number of separately represented parties;
27
(4) Coordination with related actions pending in one or more courts in other counties,
states, or countries, or in a federal court; or
28
3
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746Page 4 (5) Substantial postjudgment judicial supervision.
1
2
Cal. R. Ct. 3.400(b).
3
4
This case warrants “complex” designation under this framework. Defendants’ application
should accordingly be granted.
5
A.
This case will involve substantial pretrial motion practice.
6
Pretrial motion practice will likely be substantial and involved. Defendants intend to
7
challenge the numerous fatal procedural and substantive defects apparent on the face of the
8
complaint. Though Defendants believe early and swift dismissal is warranted, adjudication of a
9
dispositive motion will entail significant judicial resources and would benefit from assignment to
10
a dedicated judge in the Complex Department. See People v. Superior Ct. (Lavi), 4 Cal. 4th 1164,
11
1179 (1993) (“[A]ll purpose assignment . . . to a specific judge” can “permit the efficient disposition
12
of complex matters.”). Musk’s claims rest on convoluted—often incoherent—factual premises.
13
To take just one example, Musk says his Founding Agreement was “memorialized,” but any actual
14
agreement is conspicuously missing from the pleading. Compl. ¶ 25. Musk instead serves up
15
internally contradictory accounts of what documents constitute this “memorialization.” See id.
16
¶¶ 23-28, 124. Musk’s factual allegations span nearly a decade and are asserted against multiple
17
parties.
18
applicable legal principles will require time-consuming focus.
19
20
Sifting through the complaint’s sprawling allegations and mapping them onto the
Were this case to move beyond the pleading stage, further motion practice—including for
summary judgment—likewise would be substantial.
21
B.
This case will likely present significant discovery disputes.
22
Complex designation is also appropriate given the high likelihood of serious and
23
consequential discovery disputes in the event this case proceeds beyond the pleading stage. Musk
24
competes directly with OpenAI. Were discovery to commence, Musk would use this suit to seek
25
access to OpenAI’s proprietary records and technology and to press for broad merits discovery.
26
Those demands would need to be carefully policed, including through resolution of discovery
27
motions.
28
and attendant disputes would be expected as well. Assigning this case to the Complex
Given the technical facts Musk purports to put at issue, expert discovery
4
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746Page 5 1
Department would afford the Court significant power to actively manage discovery in the fair,
2
efficient, and expeditious manner necessary to safeguard OpenAI’s competitive interests against
3
Musk’s tactical discovery demands. See Hernandez v. Superior Ct., 112 Cal. App. 4th 285, 295
4
(2003) (“The trial court has broad discretion to fashion suitable methods of practice in order to
5
manage complex litigation.”); First State Ins. Co. v. Superior Ct., 79 Cal. App. 4th 324, 331-32
6
(2000) (“In complex litigation, judicial management should begin early and be applied
7
continuously and actively, based on knowledge of the circumstances of each case.” (citations and
8
alterations omitted)).
9
C.
Musk seeks extraordinary injunctive relief implicating complex facts.
10
Finally, Musk’s request for extraordinary relief entailing “[s]ubstantial postjudgment
11
judicial supervision,” Cal. R. Ct. 3.400(b)(5), counsels in favor of complex designation. The
12
complaint requests a suite of truly extraordinary measures calculated to benefit Musk, whose own
13
for-profit AI concern has not met with success in the marketplace. Musk asks for an order of
14
“specific performance” compelling OpenAI to operate and disclose its technology in accordance
15
with the terms Musk has conjured; “a judicial determination that GPT-4 constitutes Artificial
16
General Intelligence”; and other forms of atypical mandatory injunctive relief. Compl. at p. 34.
17
Were this case to move beyond the pleadings, and Musk to prevail on any of his claims, none of
18
the relief sought would be proper or warranted. But navigating the issues raised by the prayer for
19
relief in this case would benefit from the careful attention of a dedicated judge.
20
III.
21
For the foregoing reasons, Defendants’ application should be granted.
CONCLUSION
22
23
24
25
26
27
28
5
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746Page 6 1
Date: March 6, 2024
MORRISON & FOERSTER LLP
2
3
By:
JORDAN ETH
JEth@mofo.com
RAGESH K. TANGRI
RTangri@mofo.com
DAVID J. WIENER
DWiener@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
4
5
6
7
8
9
10
11
WILLIAM SAVITT
(pro hac vice application forthcoming)
SARAH K. EDDY
(pro hac vice application forthcoming)
RANDALL W. JACKSON
(pro hac vice application forthcoming)
WACHTELL, LIPTON, ROSEN & KATZ
51 West 52nd Street
New York, NY 10019
Telephone: (212) 403-1000
Facsimile: (212) 403-2000
12
13
14
15
16
17
Attorneys for Defendants
SAMUEL ALTMAN, GREGORY
BROCKMAN, OPENAI, INC., OPENAI,
LP, OPENAI, LLC, OPENAI GP, LLC,
OPENAI OPCO, LLC, OPENAI
GLOBAL LLC, OAI CORPORATION,
LLC, AND OPENAI HOLDINGS LLC
18
19
20
21
22
23
24
25
26
27
28
6
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
PDF Page 1
PlainSite Cover Page
PDF Page 2
APPLICATION FOR APPROVAL OF COMPLEX LITIGATION DESIGNATION (TRANSACTION ID # 210065985) FILED BY DEFENDANT ALTMAN, SAMUEL BROCKMAN, GREGORY OPENAI, INC. OPENAI, LP OPENAI, LLC OPENAI GP, LLC OPENAI OPCO, LLC OPENAI GLOBAL LLC OAI CORPORATION, LLC OPENAI HOLDINGS LLC: 1
2
3
4
5
6
7
8
9
10
11
12
13
14
JORDAN ETH (CA SBN 121617)
JEth@mofo.com
RAGESH K. TANGRI (CA SBN 159477)
RTangri@mofo.com
DAVID J. WIENER (CA SBN 291659)
DWiener@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105
Telephone: (415) 268-7126
Facsimile: (415) 268-7522
COUNTY OF SAN FRANCISCO
ELON MUSK, an individual,
19
Plaintiff,
v.
26
SAMUEL ALTMAN, an individual, GREGORY
BROCKMAN, an individual, OPENAI, INC., a
corporation, OPENAI, L.P., a limited partnership,
OPENAI, L.L.C., a limited liability company,
OPENAI GP, L.L.C., a limited liability company,
OPENAI OPCO, LLC, a limited liability
company, OPENAI GLOBAL, LLC, a limited
liability company, OAI CORPORATION, LLC,
a limited liability company, OPENAI
HOLDINGS, LLC, a limited liability company,
and DOES 1 through 100, inclusive,
27
Defendants.
22
23
24
25
BY: AUSTIN LAM
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
17
21
03/06/2024
Clerk of the Court
Attorneys for Defendants
SAMUEL ALTMAN, GREGORY BROCKMAN,
OPENAI, INC., OPENAI, LP, OPENAI, LLC,
OPENAI GP, LLC, OPENAI OPCO, LLC, OPENAI
GLOBAL LLC, OAI CORPORATION, LLC, AND
OPENAI HOLDINGS LLC
16
20
FILED
Superior Court of California,
County of San Francisco
William Savitt (pro hac vice application forthcoming)
Sarah K. Eddy (pro hac vice application forthcoming)
Randall W. Jackson (pro hac vice application forthcoming)
WACHTELL, LIPTON, ROSEN & KATZ
51 West 52nd Street
New York, NY 10019
Telephone: (212) 403-1000
Facsimile: (212) 403-2000
15
18
ELECTRONICALLY
Case No.: CGC-24-612746
DEFENDANTS’ APPLICATION
FOR COMPLEX DESIGNATION
Date Action Filed:
Trial Date:
28
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
February 29, 2024
None Set
PDF Page 3
1
Defendants Samuel Altman, Gregory Brockman, OpenAI, Inc., and affiliated OpenAI
2
entities (collectively, “Defendants”) respectfully submit that this action warrants dedicated judicial
3
management and for that reason request an order designating the action “complex” pursuant to
4
California Rule of Court 3.400.
5
I.
INTRODUCTION AND BACKGROUND
6
Though an early supporter and board member of OpenAI, Inc. (together with its affiliates,
7
“OpenAI”), Plaintiff Elon Musk quit the company years ago and started his own for-profit AI
8
business. Were this case to proceed to discovery, the evidence would show that Musk supported a
9
for-profit structure for OpenAI, to be controlled by Musk himself, and dropped the project when
10
his wishes were not followed. Seeing the remarkable technological advances OpenAI has achieved,
11
Musk now wants that success for himself. So he brings this action accusing Defendants of
12
breaching a contract that never existed and duties Musk was never owed, demanding relief
13
calculated to benefit a competitor to OpenAI. Musk purports to bring this suit for humanity, Compl.
14
¶ 33, when the truth—evident even from the face of Musk’s contradictory pleading—is that he
15
brings it to advance his own commercial interests.
16
According to the complaint, all Defendants entered a “Founding Agreement” with Musk,
17
Compl. ¶ 24, promising him OpenAI would never operate for profit and would release all its AI
18
publicly—promises all Defendants purportedly breached by, among other things, licensing
19
OpenAI’s core GPT-4 technology. Id. ¶¶ 123-25. Musk further claims that all Defendants breached
20
fiduciary duties and engaged in unfair business practices by using early contributions Musk made
21
to OpenAI for purposes supposedly inconsistent with this alleged “Founding Agreement.”
22
Id. ¶¶ 133-44.
23
There is no Founding Agreement, or any agreement at all with Musk, as the complaint itself
24
makes clear. The Founding Agreement is instead a fiction Musk has conjured to lay unearned claim
25
to the fruits of an enterprise he initially supported, then abandoned, then watched succeed without
26
him. The documents Musk cites as purportedly memorializing a binding contract with him—
27
OpenAI’s certificate of incorporation and a few emails—on their face show no promises to Musk.
28
2
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
PDF Page 4
1
See id. ¶¶ 23-28, 50-57, 124. The pleading nowhere alleges that Musk’s early donations were
2
conditioned on Defendants following a specific business plan, nor could it.
3
The relief Musk seeks is as extraordinary as his claims are contrived. Musk requests an
4
order compelling OpenAI to reorganize and distribute its technology in accordance with the terms
5
of his fictitious contract. And he wants a “judicial determination”—with an accompanying
6
mandatory injunction—that certain OpenAI technology “constitutes Artificial General
7
Intelligence,” i.e., “having intelligence for a wide variety of tasks like a human” (when it does not).
8
Compl. at p. 34; id. ¶ 17.
9
Frivolous though Musk’s legal claims are, “exceptional judicial management” is warranted
10
to ensure that this case is litigated efficiently, expeditiously, and fairly. See Cal. R. Ct. 3.400(a).
11
Pretrial motion practice will be intensive; the facts Musk purports to put at issue are complicated,
12
highly technical, and span nearly a decade; and the relief Musk seeks is extraordinary and if granted
13
would require ongoing supervision. These factors weigh decisively in favor of a “complex”
14
designation and assignment for all purposes to this Court’s Complex Civil Litigation Department
15
pursuant to California Rule of Court 3.400.
16
II.
17
Under the California Rules of Court, a “complex case” is one that “requires exceptional
18
judicial management to avoid placing unnecessary burdens on the court or the litigants and to
19
expedite the case, keep costs reasonable, and promote effective decision making by the court, the
20
parties, and counsel.” Cal. R. Ct. 3.400(a).
21
22
23
24
DISCUSSION
In assessing whether a case merits “complex” treatment, courts consider a non-exhaustive
list of factors, including whether it will likely involve:
(1) Numerous pretrial motions raising difficult or novel legal issues that will be
time-consuming to resolve;
25
(2) Management of a large number of witnesses or a substantial amount of documentary
evidence;
26
(3) Management of a large number of separately represented parties;
27
(4) Coordination with related actions pending in one or more courts in other counties,
states, or countries, or in a federal court; or
28
3
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
PDF Page 5
(5) Substantial postjudgment judicial supervision.
1
2
Cal. R. Ct. 3.400(b).
3
4
This case warrants “complex” designation under this framework. Defendants’ application
should accordingly be granted.
5
A.
This case will involve substantial pretrial motion practice.
6
Pretrial motion practice will likely be substantial and involved. Defendants intend to
7
challenge the numerous fatal procedural and substantive defects apparent on the face of the
8
complaint. Though Defendants believe early and swift dismissal is warranted, adjudication of a
9
dispositive motion will entail significant judicial resources and would benefit from assignment to
10
a dedicated judge in the Complex Department. See People v. Superior Ct. (Lavi), 4 Cal. 4th 1164,
11
1179 (1993) (“[A]ll purpose assignment . . . to a specific judge” can “permit the efficient disposition
12
of complex matters.”). Musk’s claims rest on convoluted—often incoherent—factual premises.
13
To take just one example, Musk says his Founding Agreement was “memorialized,” but any actual
14
agreement is conspicuously missing from the pleading. Compl. ¶ 25. Musk instead serves up
15
internally contradictory accounts of what documents constitute this “memorialization.” See id.
16
¶¶ 23-28, 124. Musk’s factual allegations span nearly a decade and are asserted against multiple
17
parties.
18
applicable legal principles will require time-consuming focus.
19
20
Sifting through the complaint’s sprawling allegations and mapping them onto the
Were this case to move beyond the pleading stage, further motion practice—including for
summary judgment—likewise would be substantial.
21
B.
This case will likely present significant discovery disputes.
22
Complex designation is also appropriate given the high likelihood of serious and
23
consequential discovery disputes in the event this case proceeds beyond the pleading stage. Musk
24
competes directly with OpenAI. Were discovery to commence, Musk would use this suit to seek
25
access to OpenAI’s proprietary records and technology and to press for broad merits discovery.
26
Those demands would need to be carefully policed, including through resolution of discovery
27
motions.
28
and attendant disputes would be expected as well. Assigning this case to the Complex
Given the technical facts Musk purports to put at issue, expert discovery
4
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
PDF Page 6
1
Department would afford the Court significant power to actively manage discovery in the fair,
2
efficient, and expeditious manner necessary to safeguard OpenAI’s competitive interests against
3
Musk’s tactical discovery demands. See Hernandez v. Superior Ct., 112 Cal. App. 4th 285, 295
4
(2003) (“The trial court has broad discretion to fashion suitable methods of practice in order to
5
manage complex litigation.”); First State Ins. Co. v. Superior Ct., 79 Cal. App. 4th 324, 331-32
6
(2000) (“In complex litigation, judicial management should begin early and be applied
7
continuously and actively, based on knowledge of the circumstances of each case.” (citations and
8
alterations omitted)).
9
C.
Musk seeks extraordinary injunctive relief implicating complex facts.
10
Finally, Musk’s request for extraordinary relief entailing “[s]ubstantial postjudgment
11
judicial supervision,” Cal. R. Ct. 3.400(b)(5), counsels in favor of complex designation. The
12
complaint requests a suite of truly extraordinary measures calculated to benefit Musk, whose own
13
for-profit AI concern has not met with success in the marketplace. Musk asks for an order of
14
“specific performance” compelling OpenAI to operate and disclose its technology in accordance
15
with the terms Musk has conjured; “a judicial determination that GPT-4 constitutes Artificial
16
General Intelligence”; and other forms of atypical mandatory injunctive relief. Compl. at p. 34.
17
Were this case to move beyond the pleadings, and Musk to prevail on any of his claims, none of
18
the relief sought would be proper or warranted. But navigating the issues raised by the prayer for
19
relief in this case would benefit from the careful attention of a dedicated judge.
20
III.
21
For the foregoing reasons, Defendants’ application should be granted.
CONCLUSION
22
23
24
25
26
27
28
5
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
PDF Page 7
1
Date: March 6, 2024
MORRISON & FOERSTER LLP
2
3
By:
JORDAN ETH
JEth@mofo.com
RAGESH K. TANGRI
RTangri@mofo.com
DAVID J. WIENER
DWiener@mofo.com
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105
Telephone: (415) 268-7000
Facsimile: (415) 268-7522
4
5
6
7
8
9
10
11
WILLIAM SAVITT
(pro hac vice application forthcoming)
SARAH K. EDDY
(pro hac vice application forthcoming)
RANDALL W. JACKSON
(pro hac vice application forthcoming)
WACHTELL, LIPTON, ROSEN & KATZ
51 West 52nd Street
New York, NY 10019
Telephone: (212) 403-1000
Facsimile: (212) 403-2000
12
13
14
15
16
17
Attorneys for Defendants
SAMUEL ALTMAN, GREGORY
BROCKMAN, OPENAI, INC., OPENAI,
LP, OPENAI, LLC, OPENAI GP, LLC,
OPENAI OPCO, LLC, OPENAI
GLOBAL LLC, OAI CORPORATION,
LLC, AND OPENAI HOLDINGS LLC
18
19
20
21
22
23
24
25
26
27
28
6
DEFENDANTS’ APPLICATION FOR COMPLEX DESIGNATION
CASE NO.: CGC-24-612746
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