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The Third Circuit affirmed that Westlaw’s editorial headnotes qualify for copyright protection and that ROSS Intelligence’s copying of those headnotes to train its competing legal‑research AI platform does not satisfy the fair‑use test. The court applied the traditional four‑factor analysis, emphasizing ROSS’s commercial, competitive purpose, the wholesale copying of entire headnotes, and the foreseeable harm to Westlaw’s market and a nascent licensing market for AI training data. While the ruling underscores that AI‑training activities are still governed by ordinary copyright law, it stops short of addressing generative large‑language models, noting that ROSS’s system did not create new expressive output. Companies building AI systems should now scrutinize whether they need copyrighted material, seek licensed or public‑domain alternatives, and evaluate the impact on existing or developing markets, while content owners are urged to register protectable elements and explore licensing AI‑training rights. [[1]]