Elizabeth Ramos v. OpenAI, Inc., et al.

Summary

The United States District Court for the Western District of Missouri grants OpenAI’s motion to dismiss Elizabeth Ramos’s Second Amended Complaint under Federal Rules of Civil Procedure 8 and 12(b)(6). The court concludes that Ramos’s claims for trade-secret misappropriation, CFAA violations, breach of contract, unjust enrichment, Missouri Merchandising Practices Act violations, emotional distress, intrusion upon seclusion, and Servicemembers Civil Relief Act violations are inadequately pleaded or legally unavailable. The case is dismissed with prejudice, and Ramos’s pending pro se motions are denied as moot.

Holdings

1. The Second Amended Complaint failed to satisfy Rule 8 because it consisted of conclusory allegations, unclear jargon, and insufficient factual support for the nine asserted causes of action.
2. The Second Amended Complaint failed to state a plausible claim for relief under Rule 12(b)(6), and dismissal of the complaint was warranted.
3. Plaintiff failed to state a trade-secret misappropriation claim under the Defend Trade Secrets Act or Missouri law because she did not adequately allege a protectable trade secret, misappropriation, or damages.
4. Plaintiff failed to state a claim under the Computer Fraud and Abuse Act because she alleged that she voluntarily entered the information into ChatGPT and did not allege unauthorized access to her computer.
5. Plaintiff failed to plead sufficient facts supporting Counts III through IX, including the required elements of each claim, and those claims were dismissed.

Questions Presented

1. Whether the Second Amended Complaint satisfied Federal Rule of Civil Procedure 8 by providing a short and plain, comprehensible statement of facts supporting Plaintiff's claims.
2. Whether the Second Amended Complaint plausibly stated a claim under Federal Rule of Civil Procedure 12(b)(6).
3. Whether Plaintiff plausibly pleaded trade-secret misappropriation under federal or Missouri law.
4. Whether Plaintiff plausibly pleaded a Computer Fraud and Abuse Act claim based on information voluntarily entered into ChatGPT.
5. Whether Plaintiff plausibly pleaded breach of contract, unjust enrichment, Missouri Merchandising Practices Act violations, intentional or negligent infliction of emotional distress, intrusion upon seclusion, or a Servicemembers Civil Relief Act violation.

Disposition

dismissed