But OpenAI actually flat-out admits the most basic premise of the complaint: that it copied the Times's work and used it to teach the ChatGPT LLM (albeit more than three years ago). ![]() Indeed, the factual background section of the motion to dismiss reads more like a press release than a legal pleading in that it introduces new factual allegations, argues that the facts alleged in the complaint are incorrect, suggests affirmative defenses, and contains an overblown self-serving assessment of the company's importance. So in the end, the motion's factual background section itself may draw the judge's wrath for a transparent attempt to circumvent the basic rules of motions to dismiss. In an attempt to do so without drawing the judge's ire, it sought to invoke several of the loopholes that allow the consideration of information outside the express language of a complaint, stretching the exceptions until they would swallow the basic rules on motions to dismiss. Instead, OpenAI ranged far afield factually, not limiting itself to the factual averments of the complaint. The court will then dismiss the complaint (or parts of it) only if those facts do not form a plausible basis for the claims asserted or if there is some legal bar to the claims that is apparent without any fact finding. That is because the court's standard in reviewing a motion to dismiss is to assume the truth of all of the facts in a well-pled complaint and all reasonable inferences drawn from those facts. Motions to dismiss generally follow a well-trodden path of reciting the factual averments of the complaint, then arguing that those facts, even in the best of circumstances for the plaintiff, do not form the basis of an actionable claim. ![]() OpenAI's motion to dismiss is noteworthy for a number of reasons. OpenAI also seeks to have portions of the direct and contributory copyright infringement claims that occurred outside of the statute of limitations dismissed as time-barred. On February 26, 2024, OpenAI responded with a motion to dismiss the claims of contributory copyright infringement (Count IV), DMCA violations (Count V), and unfair competition (Count VI). As we have discussed earlier, a notable aspect of the complaint is its specificity - particularly, it provides several examples of the ChatGPT LLM being able to reproduce Times articles almost verbatim. The Times's complaint includes counts of direct copyright infringement, vicarious copyright infringement, contributory copyright infringement, violations of the Digital Millennium Copyright Act (DMCA), unfair competition by misappropriation, and trademark dilution. District Court for the Southern District of New York, alleging that those companies have improperly trained large language models (LLMs) on the Times's copyrighted works, and that the defendants then deployed these models for public use. On December 27, 2023, the Times filed its lawsuit against Microsoft Corp. In short, the motion to dismiss seems more like an attempt to influence the public view of the Times case, rather than an effort to narrow the scope of the dispute. ![]() It sought to recast the case by including an extensive factual background that went far beyond - and sometimes is incompatible with - the allegations of the complaint. But instead of filing a traditional motion to dismiss that argues that the allegations of the complaint are insufficient to support legal liability, OpenAI went on the offensive. In response to the lawsuit the New York Times has filed against it, OpenAI has sought to dismiss portions of the complaint.
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Then give a brief (usually no more than four or five sentences long) self-contained explanation of the reasons for your conclusion. Begin with your conclusion: yes, no, probably yes, etc., if the question can be answered that way. The brief answer should clearly and fully respond to the question presented. Always include the name of the jurisdiction involved, e.g., New York, the Second Circuit. Although questions are usually framed so that they can be answered yes or no (or probably yes or probably no), sometimes they cannot (such as “Under New York law, has a retailer made a binding offer when…?”). It is usually one sentence, and often begins: “Whether….” or “Does….” The question incorporates legally relevant facts as well as the rule involved. The question presented should be sufficiently narrow and should be objective. The subject of the memo is a question: How does the relevant law apply to the key facts of the research problem? Thus, the question presented is analogous to the issue or question presented in a case brief. Put the title of each subsequent section of your memo at the beginning of that section, in all caps, and centered. RE: Name of client, and a short description of the subject matter of the memorandum TO: Name of person who assigned the research project Therefore, you need to maintain an objective tone, and remember to address any counterarguments. You are not writing to persuade a court but to predict how a court would apply the law to the facts of your situation. One final but important reminder: an office memorandum is a predictive statement of the law. Remember to keep the needs and expectations of your audience (here, a legally trained reader) in mind. Therefore, as you write, keep asking yourself: will the reader be able to follow my analysis? Have I organized my analysis to track all the steps in the “CRRACC” paradigm (conclusion-rule statement-rule explanation-application-counterargument-conclusion)? If your organization plan skips any steps of your thought process (for example, if you move directly from a bare statement of the rule to an application to your facts, without first discussing in greater depth the cases from which the rule is derived), your reader will not be able to follow your analysis and ultimately will not find your work to be useful. Your reader may have a general familiarity with the law you are discussing but may not be familiar with specific cases (or, if applicable, statutory provisions) that you have found to be relevant to the analysis. You are writing this for the benefit of another lawyer who has asked you to address a specific question and expects an answer to that question. As the list of writer’s questions included here suggests, keeping the needs and expectations of your (possibly extended) audience in mind is a key component of drafting an effective office memorandum. At the same time, it bears emphasis that the reader for whom you prepare the memorandum may be only one of several attorneys who will consult the memo, particularly if the legal question becomes the subject of litigation. The choices you make will be informed by the nature and level of complexity of the legal question, and the preferences of your intended audience, including your reader’s expected level of familiarity with the underlying area of law under discussion. There is no single version of a memorandum that will serve all situations. Even within the suggested format that we offer here, it is permissible and often appropriate to make choices – on how to frame the legal question, on the level of detail to include in the facts section, on the organization and scope of the legal discussion. When in doubt, follow the conventions chosen by the office in which you are working. Some law offices adopt their own format for a memorandum which may differ in some respects from the examples we have provided. The suggested format for a law office memorandum, structure for a working draft, a sample memorandum, and an advanced sample memorandum exemplify a conventional structure, highlighting a specific legal question and its answer, followed by a recitation of legally significant facts – the facts upon which resolution of the legal question depends – and a discussion section that identifies the applicable legal rule, applies it to the facts of the case, and addresses likely counterarguments to the principal line of analysis. If you have this kind of game file with multiple tracks:.OR, you can turn OFF the Pause when menu is actived OFF in Settings > User Interface, this way you don't need to press Resume before pressing Restart!Ĭombining multi tracks disc into a single.If you don't click Resume before Restart the CD will not load for some reason:.Go back to Quick Menu, click Resume, re-open Retroarch menu and click Restart.Click once on Disk Cycle Tray Status, select the correct disc in Disk Index and click once again on Disk Cycle Tray Status.Start your game, open Retroarch menu and go to Quick Menu > Disk Control.Go back to Quick Menu and select Resume, the correct disc should now load :).Click once on Disk Cycle Tray Status to simulate the opening of the CD drive, then select the correct disc in Disk Index, and finally click once again on Disk Cycle Tray Status to close the virtual CD drive.When the game asks you to change disc, open Retroarch menu (start+select) then go to Quick Menu > Disk Control.cue files of your game and paste them to the CLV-* folder matching the ID of the "game" we just added with hakchi2. Check the ID of the game in top-right and close hakchi2. m3u file we just created, uncheck "Compress", change the command line, add your box art, etc. If done correctly it should look like this:.and make sure All files is selected in Save as type, type the name of your game in File Name (no () and/or characters) followed by the. cue file, hit enter to go to the next line a copy/paste the name of the CD2. Open a text editor and copy/paste the name of the CD1.Multiple CDs in a playlist without converting in EBOOT format ( video here if needed): Restart hakchi2 and sync your games or do it manually: copy/paste the CLV-* folder of the game to usb:\hakchi\games folder (or usb:\hakchi\games\00* if you want to put the game in a subfolder).pbp file, go to \hakchi2\games_snes, go to the CLV-* folder matching the ID of the "game" we just added with hakchi2 and paste your. pbp file we just created, uncheck "Compress", change the command line, add your box art, etc. and make sure All files is selected in Save as type, paste the file name of your PS1 game in File name and save (in a different directory as your real. Open a text editor and start typing random letters or numbers, really it doesnt matter what you're typing, we just need a non-blank file.If your file is >2GB ( video here if needed): Add art, change your command line, etc.Open hakchi2, go to settings and uncheck Compress games when adding, then click Add games, select All files (*.*) in bottom-right and select your.for my example I renamed EBOOT.PBP in Final_Fantasy_VIII.pbp I highly recommend to rename EBOOT.PBP in something else, because when you'll add multiple games and you want to make a Game Overrides config it will be saved as EBOOT.cfg so your config will be loaded for every games named EBOOT :/ĭo not use special characters, use _ instead of space, etc.OK, now you should have EBOOT.PBP on the newly created folder, containing all the CDs at once!.Click Convert and wait, this may take a while depending on the size and the number of CDs. ![]() ![]() In Output PBP folder chose where you want to save your file.(optional) Personally in Options > Folders I checked Create main game title folder, this way the folder will be created with the game name instead of the ID, I think it's easier to navigate.Select ISO/PBP File 3 and load 3rd CD, etc.Open PSX2PSP, on top-left click the 3 dots next to ISO/PBP File 1 and chose the first CD of your game.Multiple CDs in one PBP file ( video here if needed): A quick guide on how to play games with multiple CD on you SNESC, this guide is made for USB-HOST for obvious reasons :o But if you managed to shrink the game enough it should work for non-USB SNESC. 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Woodys quick thinking saves the gang, but all but Woody end up being donated to a day-care center. Woody, Buzz and the other toys end up here as a result of Lotso's betrayal and face certain, inevitable death until they are rescued by the Aliens operating a giant claw. With their beloved Andy preparing to leave for college, Woody, Buzz Lightyear, Jessie, and the rest of the toys find themselves headed for the attic but mistakenly wind up on the curb with the trash. This is where garbage, cascading down an enormous bowl, is burned to ashes by an incinerator at the very center of the bowl. Slinky gets pulled to the ceiling, prompting the toys to rescue him.Īndy's toys as they almost go into the incinerator at the landfill. To avoid the shredders, the toys must grab metal objects that pull them to the magnetic ceiling. There is a magnetic ceiling that pulls metal objects from a bottom conveyor belt full of garbage. The shredders crush large objects into small chunks. He is a large, pink strawberry-scented teddy bear who used to rule Sunnyside Daycare like a prison with his former minions. Bulldozers plow garbage onto a conveyor belt that leads to the following locations below. For now though, we’re looking at the scary side of Toy Story 3, as evidenced in the film’s various homages and influences in horror cinema.For starters, there’s the influence of director Lee. 'Im Lots-o-Huggin-Bear, but please call me Lotso.' Lotso introduces himself to Andys toys Lots-o-Huggin Bear ('Lotso' for short) is one of the main characters in Toy Story 3. Lotso, Woody, Buzz Lightyear and the other toys get dumped here. It certainly comes from one of the year’s best films. It is also where Lotso is found and picked up by a garbage man who had once had another one like him when he was a kid.This is where garbage trucks, property of Tri-County Sanitation, dump garbage from Tri-County Area. (US) Though it’s barely two months old, it is time to declare a best scene of Summer 2010. ![]() incinerator, we fear it could be renamed Toy Story Triage. The claw carries the toys here and they, after rejoining with the aliens, hitch a ride home via Sid's garbage truck. Toy Story 3 his cell phone to explain to Madame Longray why he. Woody, Buzz, and the other toys end up here as a result of Lotso's betrayal and face certain, inevitable death until they are rescued by the aliens operating a giant claw. ![]() ![]() To avoid the shredders, the toys must grab metal objects that pull them to the magnetic ceiling.Īndy's toys as they almost go into the incinerator at the landfill. Bulldozers plow garbage onto a conveyor belt that leads to the following locations below. Lotso, Woody, Buzz Lightyear, and the other toys get dumped here. This is where garbage trucks, property of Tri-County Sanitation, dump garbage from Tri-County Area. The climactic scene where Lotso leaves the toys to die in the trash incinerator, which is likely the closest thing to Dantes Inferno youll ever see in a kids movie. ![]() When clicking on "Hint", moveable cards are marked with two different colors. At this point, if the player can move cards around and remove all cards from the Tableau, the game is won. This process of moving suited runs and initiating the next deal continues until there are no more piles left in the Stock. When all cards have been moved to the player's liking within the Tableau, they must click on the rightmost pile in the Stock to initiate the next deal. If onto another pile, the target card must be next in rank to the highest ranking card being moved however, it does not necessarily need to be the same suit. The rules of the game allow any suited run to be placed into an empty column.Ī suited run in the Tableau may be moved from the bottom of one pile and either into a vacant column or onto the bottom-most card in another pile. When the player manages to arrange a complete suited run from the King down to the Ace, it is automatically placed into a foundation location for storage.Ī column that contains no cards is said to be empty or vacant. All the cards being moved must be the same suit and, from up to down on the screen, must be descending in rank. In Spider Solitaire, groups of one or more consecutive cards are moved at a time within the Tableau. This brings the card into play and can then be moved when appropriate. A card is turned (or flipped) automatically when all cards atop of it are removed. Part of what has to be done to win a game is for the player to turn (cause to become visible) all 44 hidden cards in the Tableau. The remaining 50 cards are sent to the Stock. Only the top (bottom-most on-screen) card in each pile is face-up (visible) while all the rest are face-down (hidden or invisible). When the game starts, a pile of 54 cards is dealt into each Tableau column, 6 into the leftmost 4 columns, and 5 into the remaining 6 columns. Spider Solitaire is played with two decks of standard playing cards, for a total of 104 cards. In effect, the goal is to empty the Tableau of all cards. The goal of Spider Solitaire is to build all 8 ordered suits from King down to Ace in the Tableau, each ordered suit is automatically sent to a foundation as it's completed. It's still one of the most played solitaire games today. The computerized version became very popular following its inclusion into Microsoft's Windows 98 Plus. Spider Solitaire is said to have gotten its name from the fact that spiders have 8 legs and the game has 8 foundations. It's played with 52 Hearts and 52 Spades. This version is meant for the intermediate player. Most prefer the Intermediate level, which is played with 2 suits. The Advanced level is played with all 4 suits and is rather difficult to beat. The Beginner level is played with only 1 suit and is relatively easy to beat. There are three different levels of difficulty. ![]() The game is played with two 52-card decks of standard playing cards. However, if one is not into hard thinking and just wants to relax and be entertained, the game can be played at an easy level. It's a complex game that requires problem-solving skills to master. Spider Solitaire is a popular card game played around the world. ![]() However, a 2017 hacking incident made waves, by tricking users into clicking a fake ad. This site is one of the most widely recognized porn brands and even makes mainstream news occasionally with creative campaigns. Premium videos are of higher quality and variety, along with VR tie-ins.View free videos and pictures as a member or a visitor.Pornhub Premium – Best Free Safe Porn Site As well as it’s stellar reviews on both the free and premium versions of the website. We chose PornHub Premium as our top site for its ability to remove ads (which may be infected with trojan horse software), inability to create unique tags (which also may be encrypted), and lack of messaging features. Fraudulent Charge History (Based on actual consumer reviews and complaints). ![]() ![]() Database Security and technology (What do they do to protect themselves?).Hacking attempts (And whether customer data was leaked).Virus History (How many times a virus disrupted their operation).When creating our list, we avoided all the hundreds of hours of porn going on in the background and instead paid attention to these important factors: Below features a dive into all of the recent breaches as well as what websites are best positioned against these Our Review Process Malicious ads, messages disguised as pretty girls, porn tags, and homescreens have all been weaponized. New techniques pop up everyday as this 2020 report on recent ddos attacks by Kaspersky shows. New studies suggest internet viruses are still raging on, stealing credit card numbers, holding computers hostage for cash, and even blackmailing us at our most vulnerable.Īnd while most people assume the golden age of online viruses and malware was in the 1990s and the first 2000 decades, large attacks have still happened on major porn sites within the last two years. ![]() The ever-expanding international team of iNKPPL Tattoo Magazine works so that you can completely immerse yourself in the incredible diversity of the world of tattoos. We’ve added a Marker set for those who miss. We provide inspiration and practical knowledge from the field of tattooing. New free brush sets are now available for Sketchbook Pro While the team is busy working on the next updates, we thought now would be a great time to get some new brush sets out to you while you wait (plus, creating new brush sets doesn’t require taking a developer off feature work ). More than 1,000,000 exclusive tattoos are already presented on the pages of the magazine, and this number is growing every day. We cover thematic tattoo conventions and festivals, make photo reports and present event winners. We conduct exclusive interviews with world tattoo stars. We highlight modern trends in the art of tattooing, covering all areas, from classical to conceptual design styles. We acquaint readers with the latest products and developments of the industry, which are used both among tattooists and their clients. In this video im showing my sketchbook tour.Youll see all kind sketches from illustration to traditional tattoo flash designs and lot of practice work and. We write about talented newcomers and professionals of the tattoo community. ONLINE SCHOOL & TRAINING FOR TODAYS TATTOO ARTIST. Youll find inspiration, art and ideas by the most talented Tattoo Artists. 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Phaedra, held captive nearby, sees a vision of Theseus embracing Hyperion, she and her sisters then attack Hyperion's guards, provoking a riot. Zeus himself has trained Theseus in the guise of the Old Man, but reasons he has helped him as a human as opposed to a god. ![]() Unless the Titans are released, they must have faith in mankind's free will to defeat Hyperion. The Olympians, especially Athena, are sympathetic to the humans suffering at Hyperion's hands, but are forbidden by Zeus from interfering in mortal affairs. Hyperion attacks Theseus' village Theseus kills many of his men before being captured, and is forced to watch as Hyperion murders Aethra. He and his mother Aethra are outcasts due to Theseus being a bastard child. Theseus is a hoplite trained by the Old Man, who says Theseus has been chosen by the gods. In 1228 BC, the genocidal king Hyperion searches for the bow to release the Titans to this end, he captures the virgin oracle Phaedra, to use her dreams and visions to find it. When the Twelve Olympians imprisoned the traitorous Titans beneath Mount Tartarus, they lost the Epirus Bow. Premiering in Los Angeles on November 8, 2011, the film received mixed reviews with critics praising Tarsem's direction and visuals, the ensemble cast, action sequences, production and costume design, and music score, but criticized the film's storytelling and the lack of character development. The film was released on Novemby Relativity Media, becoming a commercial success at the box office by grossing over $226 million. Principal photography began in Montreal on April 5, 2010. Loosely based on the Greek myths of Theseus and the Minotaur, and the Titanomachy, The film was previously named Dawn of War and War of the Gods before being officially named Immortals. Immortals is a 2011 American fantasy action film directed by Tarsem Singh Dhandwar and starring Henry Cavill, Stephen Dorff, Luke Evans, John Hurt, Isabel Lucas, Kellan Lutz, Freida Pinto, Joseph Morgan, Daniel Sharman, and Mickey Rourke. |
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