<p>When The Machine Reads Everything: A Case Review of Bartz v Anthropic Pbc and the Emerging Jurisprudence on Artificial Intelligence and Copyright Law</p>

In June 2025, the United States District Court for the Northern District of California delivered the first substantive judicial ruling on whether training a generative artificial intelligence model on copyrighted books constitutes fair use. The resulting decision in Bartz v Anthropic PBC drew a sharp doctrinal line between the transformative use of copyrighted material and the unlawful means by which that material was acquired, a distinction that culminated in a $1.5 billion settlement, the largest copyright recovery in history. This review examines the reasoning underlying that decision, situates it within the broader landscape of generative artificial intelligence litigation, and considers how the same facts would likely be treated under Nigeria's Copyright Act 2022 and the wider African fair dealing tradition. It argues that the flexible, open-textured fair use doctrine that rescued Anthropic's training practices has no true analogue in Nigerian law, and that this asymmetry carries significant implications for the development of an indigenous artificial intelligence industry in Nigeria and across the African continent.