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CLASS ACTION COMPLAINT
Clarkson Law Firm, P.C. | 22525 Pacific Coast Highway, Malibu, CA 90265 | P: (213) 788-4050 F: (213) 788-4070 | clarksonlawfirm.com
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i. California Non-User SubClass: All persons within the State of
California whose PII, Personal Information, or Private Information
was disclosed to, or accessed, collected, tracked, taken, or used by
Defendants without consent or authorization.
ii. California ChatGPT User SubClass: All persons within the State
of California who used ChatGPT, whose Private Information was
disclosed to, or intercepted, accessed, collected, tracked, taken, or
used by Defendants without consent or authorization.
iii. California ChatGPT Plus User SubClass: All persons within the
State of California who used Chat-GPT website or mobile app and
whose Personal Information or PII was intercepted, accessed,
collected, tracked, stored, shared, taken, or used by Defendants
without consent and/or authorization.
iv. California Minor User SubClass: All persons within the State of
California who, while 16 years or younger, used ChatGPT, or other
platforms, programs, or applications which integrated ChatGPT API
or ChatGPT Plug-In, whose Private Information was disclosed to,
or intercepted, accessed, collected, tracked, taken, or used by
Defendants without consent or authorization.
The New York Subclass
i. New York Non-User SubClass: All persons within the State of
New York whose PII, Personal Information, or Private Information
was disclosed to, or accessed, collected, tracked, taken, or used by
Defendants without consent or authorization.
ii. New York ChatGPT User SubClass: All persons within the State
of New York who used ChatGPT, whose Private Information was
disclosed to, or intercepted, accessed, collected, tracked, taken, or
used by Defendants without consent or authorization.
iii. New York ChatGPT Plus User SubClass: All persons within the
State of New York who used Chat-GPT website or mobile app and
whose Personal Information or PII was intercepted, accessed,
collected, tracked, stored, shared, taken, or used by Defendants
without consent and/or authorization.
v. New York Minor User SubClass: All persons within the State of
New York who, while 16 years or younger, used ChatGPT, or other
platforms, programs, or applications which integrated ChatGPT API
or ChatGPT Plug-In, whose Private Information was disclosed to,
or intercepted, accessed, collected, tracked, taken, or used by
Defendants without consent or authorization.
The Illinois Subclass
i. Illinois Non-User SubClass: All persons within the State of Illinois
whose PII, Personal Information, or Private Information was
disclosed to, or accessed, collected, tracked, taken, or used by
Defendants without consent or authorization.
ii. Illinois ChatGPT User SubClass: All persons within the State of
Illinois who used ChatGPT, whose Private Information was
Case 3:23-cv-03199 Document 1 Filed 06/28/23 Page 96 of 157