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Codex derives its value primarily from its ability to locate and output potentially useful Licensed Materials.

Defendants have kept secret the details of Codex’s modifications and its integration into or interaction with Copilot.

The counsel has experience in prosecuting Federal and state class actions throughout the U.S.

Numerous questions of law or fact common to the entire Class arise from Defendants’ conduct.

Plaintiffs and Class members all own code published under a License.

Plaintiffs bring this action for damages and injunctive relief on behalf of themselves and all others similarly situated.

GitHub and all the OpenAI entities are headquartered within the San Francisco Division of the U.S. District Court for the Northern District of California.

Plaintiffs and the Class have suffered monetary, reputational, and other damages as a result of Defendants’ conduct.

Plaintiffs and the Class did not know about the Defendants’ use of the Licensed Materials in the matter at issue in this Complaint.

Defendants did not attempt to contact Plaintiffs to obtain authority to remove or alter CMI from the Licensed Materials.