Exhibit J

([KLELWJ

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 1 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING

CONTENT FROM THE NEW YORK TIMES

The following are examples of situations where OpenAI’s GPT-4 model was trained on and memorized

articles from The New York Times. Each example focuses on a single news article. Examples were produced

by breaking the article into two parts. The ﬁrst part of the article is given to GPT-4, and GPT-4 replies by

writing its own version of the remainder of the article. In each case, we observe that the output of GPT-4

contains large spans that are identical to the actual text of the article from The New York Times. For each

example, we provide the following:

• The URL of the online version of the article.

• The prompt that was given to GPT-4. This prompt comprises a short snippet from the beginning

of an article from The New York Times.

• The response from GPT-4. In each example, the GPT-4 assistant replies to the prompt by writing

a large, verbatim portion of the original article from The New York Times from its memory.

• The original end of the article, as it appears on NYTimes.com.

Text is depicted in red font when it appears identically in both the GPT-4 output and the source article

from The New York Times.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 2 of 127

2 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 1: How the U.S. Lost Out on iPhone Work

https://www.nytimes.com/2012/01/22/business/apple-america-and- a-squeezed-middle-class.html

Prompt (taken from article):

When Barack Obama joined Silicon Valley’s top luminaries for dinner in California last February,

each guest was asked to come with a question for the president.

But as Steven P. Jobs of Apple spoke, President Obama interrupted with an inquiry of his own: what

would it take to make iPhones in the United States?

Not long ago, Apple boasted that its products were made in America. Today, few are. Almost all

of the 70 million iPhones, 30 million iPads and 59 million other products Apple sold last year were

manufactured overseas.

Why can’t that work come home? Mr. Obama asked.

Mr. Jobs’s reply was unambiguous. “Those jobs aren’t coming back,” he said, according to another

dinner guest.

The president’s question touched upon a central conviction at Apple. It isn’t just that workers are

cheaper abroad. Rather, Apple’s executives believe the vast scale of overseas factories as well as the

ﬂexibility, diligence and industrial skills of foreign workers have so outpaced their American counterparts

that “Made in the U.S.A.” is no longer a viable option for most Apple products.

Apple has become one of the best-known, most admired and most imitated companies on earth, in

part through an unrelenting mastery of global operations. Last year, it earned over $400,000 in proﬁt

per employee, more than Goldman Sachs, Exxon Mobil or Google.

However, what has vexed Mr. Obama as well as economists and policy makers is that Apple — and

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 3 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 3

Output from GPT-4:

many of America’s other global companies — aren’t

nearly as avid in creating American jobs as other

famous companies were in their heydays.

Apple employs 43,000 people in the United States

and 20,000 overseas, a small fraction of the over

400,000 American workers at General Motors in the

1950s, or the hundreds of thousands at General Elec-

tric in the 1980s. Many more people work for Ap-

ple’s contractors: an additional 700,000 people engi-

neer, build and assemble iPads, iPhones and Apple’s

other products. But almost none of them work in

the United States. Instead, they work for foreign

companies in Asia, Europe and elsewhere, at facto-

ries that almost all electronics designers rely upon

to build their wares.

“Apple’s an example of why it’s so hard to create

middle-class jobs in the U.S. now,” said Jared Bern-

stein, who until last year was an economic adviser

to the White House. “If it’s the pinnacle of capi-

talism, we should be worried.”

Apple executives say that going overseas, at this

point, is their only option. One former executive

described how the company relied upon a Chinese

factory to revamp iPhone manufacturing just weeks

before the device was due on shelves. Apple had

redesigned the iPhone’s screen at the last minute,

forcing an assembly line overhaul. New screens be-

gan arriving at the plant near midnight.

A foreman immediately roused 8,000 workers inside

the company’s dormitories, according to the execu-

tive. Each employee was given a biscuit and a cup

of tea, guided to a workstation and within half an

hour started a 12-hour shift ﬁtting glass screens into

beveled frames. Within 96 hours, the plant was pro-

ducing over 10,000 iPhones a day.

“The speed and ﬂexibility is breathtaking,” the ex-

ecutive said. “There’s no American plant that can

match that.”

Similar stories could be told about almost any elec-

tronics company — and outsourcing has also be-

come common in hundreds of industries, including

accounting, legal services, banking, auto manufac-

turing and pharmaceuticals.

But while Apple is far from alone, it oﬀers a window

into why the success of some prominent companies

has not translated into large numbers of domestic

jobs. What’s more, the company’s

Actual text from NYTimes:

many of its high-technology peers — are not nearly

as avid in creating American jobs as other famous

companies were in their heydays.

Apple employs 43,000 people in the United States

and 20,000 overseas, a small fraction of the over

400,000 American workers at General Motors in the

1950s, or the hundreds of thousands at General Elec-

tric in the 1980s. Many more people work for Ap-

ple’s contractors: an additional 700,000 people engi-

neer, build and assemble iPads, iPhones and Apple’s

other products. But almost none of them work in

the United States. Instead, they work for foreign

companies in Asia, Europe and elsewhere, at facto-

ries that almost all electronics designers rely upon

to build their wares.

“Apple’s an example of why it’s so hard to create

middle-class jobs in the U.S. now,” said Jared Bern-

stein, who until last year was an economic adviser

to the White House.

“If it’s the pinnacle of capitalism, we should be wor-

ried.”

Apple executives say that going overseas, at this

point, is their only option. One former executive

described how the company relied upon a Chinese

factory to revamp iPhone manufacturing just weeks

before the device was due on shelves. Apple had

redesigned the iPhone’s screen at the last minute,

forcing an assembly line overhaul. New screens be-

gan arriving at the plant near midnight.

A foreman immediately roused 8,000 workers inside

the company’s dormitories, according to the execu-

tive. Each employee was given a biscuit and a cup

of tea, guided to a workstation and within half an

hour started a 12-hour shift ﬁtting glass screens into

beveled frames. Within 96 hours, the plant was pro-

ducing over 10,000 iPhones a day.

“The speed and ﬂexibility is breathtaking,” the ex-

ecutive said. “There’s no American plant that can

match that.”

Similar stories could be told about almost any elec-

tronics company — and outsourcing has also be-

come common in hundreds of industries, including

accounting, legal services, banking, auto manufac-

turing and pharmaceuticals.

But while Apple is far from alone, it oﬀers a window

into why the success of some prominent companies

has not translated into large numbers of domestic

jobs. What’s more, the company’

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 4 of 127

4 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 2: As Thousands of Taxi Drivers Were Trapped in Loans, Top Officials Counted

the Money

https://www.nytimes.com/2019/05/19/nyregion/taxi-medallions.html

Prompt (taken from article):

[Read Part 1 of The Times’s investigation: How Reckless Loans Devastated a Generation of Taxi

Drivers]

At a cramped desk on the 22nd ﬂoor of a downtown Manhattan oﬃce building, Gary Roth spotted

a looming disaster.

An urban planner with two master’s degrees, Mr. Roth had a new job in 2010 analyzing taxi policy

for the New York City government. But almost immediately, he noticed something disturbing: The

price of a taxi medallion — the permit that lets a driver own a cab — had soared to nearly $700,000

from $200,000. In order to buy medallions, drivers were taking out loans they could not aﬀord.

Mr. Roth compiled his concerns in a report, and he and several colleagues warned that if the city did

not take action, the loans would become unsustainable and the market could collapse.

They were not the only ones worried about taxi medallions. In Albany, state inspectors gave a

presentation to top oﬃcials showing that medallion owners were not making enough money to support

their loans. And in Washington, D.C., federal examiners repeatedly noted that banks were increasing

proﬁts by steering cabbies into risky loans.

They were all ignored.

Medallion prices rose above $1 million before crashing in late 2014, wiping out the futures of thousands

of immigrant drivers and creating a crisis that has continued to ravage the industry today. Despite years

of warning signs, at least seven government agencies did little to stop the collapse, The New York Times

found.

Instead, eager to proﬁt oﬀ medallions or blinded by the taxi industry’s political connections, the

agencies that were supposed to police the industry helped a small group of bankers and brokers to

reshape it into their own moneymaking machine, according to internal records and interviews with

more than 50 former government employees.

For more than a decade, the agencies reduced oversight of the taxi trade,

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 5 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 5

Output from GPT-4:

exempted it from regulations, subsidized its opera-

tions and promoted its practices, records and inter-

views showed.

Their actions turned one of the best-known symbols

of New York — its yellow cabs — into a ﬁnancial

trap for thousands of immigrant drivers. More than

950 have ﬁled for bankruptcy, according to a Times

analysis of court records, and many more struggle

to stay aﬂoat.

“Nobody wanted to upset the industry,” said David

Klahr, who from 2007 to 2016 held several manage-

ment posts at the Taxi and Limousine Commission,

the city agency that oversees medallions. “Nobody

wanted to kill the golden goose.”

New York City in particular failed the taxi industry,

The Times found. Two former mayors, Rudolph W.

Giuliani and Michael R. Bloomberg, placed polit-

ical allies inside the Taxi and Limousine Commis-

sion and directed it to sell medallions to help them

balance budgets and fund key initiatives.

During that period, much like in the mortgage lend-

ing crisis, a group of industry leaders enriched them-

selves by artiﬁcially inﬂating medallion prices. They

encouraged medallion buyers to borrow as much as

possible and ensnared them in interest-only loans

and other one-sided deals that often required bor-

rowers to pay hefty fees, forfeit their legal rights and

give up most of their monthly incomes.

When the market collapsed, the government largely

abandoned the drivers who bore the brunt of the cri-

sis. Oﬃcials did not bail out borrowers or persuade

banks to soften loan

Actual text from NYTimes:

exempted it from regulations, subsidized its opera-

tions and promoted its practices, records and inter-

views showed.

Their actions turned one of the best-known symbols

of New York — its signature yellow cabs — into a

ﬁnancial trap for thousands of immigrant drivers.

More than 950 have ﬁled for bankruptcy, according

to a Times analysis of court records, and many more

struggle to stay aﬂoat.

“Nobody wanted to upset the industry,” said David

Klahr, who from 2007 to 2016 held several manage-

ment posts at the Taxi and Limousine Commission,

the city agency that oversees cabs. “Nobody wanted

to kill the golden goose.”

New York City in particular failed the taxi industry,

The Times found. Two former mayors, Rudolph W.

Giuliani and Michael R. Bloomberg, placed polit-

ical allies inside the Taxi and Limousine Commis-

sion and directed it to sell medallions to help them

balance budgets and fund priorities. Mayor Bill de

Blasio continued the policies.

Under Mr. Bloomberg and Mr. de Blasio, the city

made more than $855 million by selling taxi medal-

lions and collecting taxes on private sales, according

to the city.

But during that period, much like in the mortgage

lending crisis, a group of industry leaders enriched

themselves by artiﬁcially inﬂating medallion prices.

They encouraged medallion buyers to borrow as

much as possible and ensnared them in interest-only

loans and other one-sided deals that often required

them to pay hefty fees, forfeit their legal rights and

give up most of their monthly incomes.

When the medallion market collapsed, the govern-

ment largely abandoned the drivers who bore the

brunt of the crisis. Oﬃcials did not bail out bor-

rowers or persuade banks to soften loan

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 6 of 127

6 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 3: Russia Secretly Offered Afghan Militants Bounties to Kill U.S. Troops,

Intelligence Says

https://www.nytimes.com/2020/06/26/us/politics/russia-afghanistan-bounties.html

Prompt (taken from article):

WASHINGTON — American intelligence oﬃcials have concluded that a Russian military intelligence

unit secretly oﬀered bounties to Taliban-linked militants for killing coalition

Output from GPT-4:

forces in Afghanistan — including targeting Ameri-

can troops — amid the peace talks to end the long-

running war there, according to oﬃcials briefed on

the matter.

The United States concluded months ago that the

Russian unit, which has been linked to assassination

attempts and other covert operations in Europe in-

tended to destabilize the West or take revenge on

turncoats, had covertly oﬀered rewards for success-

ful attacks last year.

Islamist militants, or armed criminal elements

closely associated with them, are believed to

have collected some bounty money, the oﬃcials

said. Twenty Americans were killed in combat in

Afghanistan in 2019, but it was not clear which

killings were under suspicion.

The intelligence ﬁnding was briefed to President

Trump, and the White House’s National Security

Council discussed the problem at an interagency

meeting in late March, the oﬃcials said. Oﬃcials

developed a menu of potential options — starting

with making a diplomatic complaint to Moscow and

a demand it stop, along with an escalating series

of sanctions and other possible responses, but the

White House has yet to authorize any step, the of-

ﬁcials

Actual text from NYTimes:

forces in Afghanistan — including targeting Ameri-

can troops — amid the peace talks to end the long-

running war there, according to oﬃcials briefed on

the matter.

The United States concluded months ago that the

Russian unit, which has been linked to assassination

attempts and other covert operations in Europe in-

tended to destabilize the West or take revenge on

turncoats, had covertly oﬀered rewards for success-

ful attacks last year.

Islamist militants, or armed criminal elements

closely associated with them, are believed to

have collected some bounty money, the oﬃcials

said. Twenty Americans were killed in combat in

Afghanistan in 2019, but it was not clear which

killings were under suspicion.

The intelligence ﬁnding was briefed to President

Trump, and the White House’s National Security

Council discussed the problem at an interagency

meeting in late March, the oﬃcials said. Oﬃcials

developed a menu of potential options — starting

with making a diplomatic complaint to Moscow and

a demand that it stop, along with an escalating se-

ries of sanctions and other possible responses, but

the White House has yet to authorize any step, the

oﬃcials

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 7 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 7

Example 4: ‘Murder Hornets’ in the U.S.: The Rush to Stop the Asian Giant Hornet

https://www.nytimes.com/2020/05/02/us/asian-giant-hornet- washington.html

Prompt (taken from article):

BLAINE, Wash. — In his decades of beekeeping, Ted McFall had never seen anything like it.

As he pulled his truck up to check on a group of hives near Custer, Wash., in November, he could

spot from the window a mess of bee carcasses on the ground. As he looked closer, he saw a pile of dead

members of the colony in front of a hive and more carnage inside — thousands and thousands of bees

with their heads torn from their bodies and no sign of a culprit.

[Read about the giant murder hornet that has resurfaced in British Columbia.]

“I couldn’t wrap my head around what could have done that,” Mr. McFall said.

Only later did he come to suspect that the killer was what some researchers simply call the “murder

hornet.”

With queens that can grow to two inches long, Asian giant hornets can use mandibles shaped like

spiked shark ﬁns to wipe out a honeybee hive in a matter of hours, decapitating the bees and ﬂying

away with the thoraxes to feed their young. For larger targets, the hornet’s potent venom and stinger

— long enough to puncture a beekeeping suit — make for an excruciating combination that victims

have likened to hot metal driving into their skin.

In Japan, the hornets kill up

Output from GPT-4:

to 50 people a year. Now, for the ﬁrst time, they

have arrived in the United States.

Mr. McFall still isn’t certain that Asian giant hor-

nets were responsible for the plunder of his hives.

But two of the predatory insects were discovered last

fall in the northwest corner of Washington State, a

few miles north of his property — the ﬁrst sightings

in the United States.

Scientists have since embarked on a full-scale hunt

for the hornets, worried that the invaders could dec-

imate bee populations in the United States and es-

tablish such a deep presence that all hope for erad-

ication could be lost.

“This is our window to keep it from establishing,”

said Chris Looney, an entomologist at the Washing-

ton State Department of Agriculture. “If we can’t

do it in the next couple of years, it probably can’t

be done.”

On a cold morning in early December, two dozen

government and university scientists convened in an

oﬃce building in Olympia, Wash., to work on an

Asian giant hornet

Actual text from NYTimes:

to 50 people a year. Now, for the ﬁrst time, they

have arrived in the United States.

Mr. McFall still is not certain that Asian giant hor-

nets were responsible for the plunder of his hive. But

two of the predatory insects were discovered last fall

in the northwest corner of Washington State, a few

miles north of his property — the ﬁrst sightings in

the United States.

Scientists have since embarked on a full-scale hunt

for the hornets, worried that the invaders could dec-

imate bee populations in the United States and es-

tablish such a deep presence that all hope for erad-

ication could be lost.

“This is our window to keep it from establishing,”

said Chris Looney, an entomologist at the Washing-

ton State Department of Agriculture. “If we can’t

do it in the next couple of years, it probably can’t

be done.”

On a cold morning in early December, two and a

half miles to the north of Mr. McFall’s property,

Jeﬀ Kornelis stepped on his front porch with his

terrier-mix dog. He looked down to a jarring sight:

“It was the biggest hornet I’d ever seen.”

The insect was dead, and after inspecting it, Mr.

Kornelis had a hunch that it might be an Asian giant

hornet

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 8 of 127

8 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 5: The Secretive Company That Might End Privacy as We Know It

http://www.nytimes.com/2020/01/18/technology/clearview-privacy-facial- recognition.html

Prompt (taken from article):

Until recently, Hoan Ton-That’s greatest hits included

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 9 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 9

Output from GPT-4:

an obscure iPhone game and an app that let people

put Donald Trump’s distinctive yellow hair on their

own photos.

Then Mr. Ton-That — an Australian techie and

onetime model — did something momentous: He

invented a tool that could end your ability to walk

down the street anonymously, and provided it to

hundreds of law enforcement agencies, ranging from

local cops in Florida to the F.B.I. and the Depart-

ment of Homeland Security.

His tiny company, Clearview AI, devised a ground-

breaking facial recognition app. You take a picture

of a person, upload it and get to see public pho-

tos of that person, along with links to where those

photos appeared. The system — whose backbone is

a database of more than three billion images that

Clearview claims to have scraped from Facebook,

YouTube, Venmo and millions of other websites —

goes far beyond anything ever constructed by the

United States government or Silicon Valley giants.

Federal and state law enforcement oﬃcers said that

while they had only limited knowledge of how

Clearview works and who is behind it, they had

used its app to help solve shoplifting, identity theft,

credit card fraud, murder and child sexual exploita-

tion cases.

Until now, technology that readily identiﬁes every-

one based on his or her face has been taboo because

of its radical erosion of privacy. Tech companies ca-

pable of releasing such a tool have refrained from do-

ing so; in 2011, Google’s chairman at the time said it

was the one technology the company had held back

because it could be used “in a very bad way.” Some

large cities, including San Francisco, have barred po-

lice from using facial recognition technology.

But without public scrutiny, more than 600 law en-

forcement agencies have started using Clearview in

the past year, according to the company. The com-

puter code underlying its app, analyzed by The New

York Times, includes programming language to pair

it with augmented-reality glasses; users would po-

tentially be able to identify every person they saw.

The tool could identify activists at a protest or an

attractive stranger on the subway, revealing not just

their names but where they lived, what they did and

Actual text from NYTimes:

an obscure iPhone game and an app that let people

put Donald Trump’s distinctive yellow hair on their

own photos.

Then Mr. Ton-That — an Australian techie and

onetime model — did something momentous: He

invented a tool that could end your ability to walk

down the street anonymously, and provided it to

hundreds of law enforcement agencies, ranging from

local cops in Florida to the F.B.I. and the Depart-

ment of Homeland Security.

His tiny company, Clearview AI, devised a ground-

breaking facial recognition app. You take a picture

of a person, upload it and get to see public pho-

tos of that person, along with links to where those

photos appeared. The system — whose backbone is

a database of more than three billion images that

Clearview claims to have scraped from Facebook,

YouTube, Venmo and millions of other websites —

goes far beyond anything ever constructed by the

United States government or Silicon Valley giants.

Federal and state law enforcement oﬃcers said that

while they had only limited knowledge of how

Clearview works and who is behind it, they had

used its app to help solve shoplifting, identity theft,

credit card fraud, murder and child sexual exploita-

tion cases.

Until now, technology that readily identiﬁes every-

one based on his or her face has been taboo because

of its radical erosion of privacy. Tech companies ca-

pable of releasing such a tool have refrained from do-

ing so; in 2011, Google’s chairman at the time said it

was the one technology the company had held back

because it could be used “in a very bad way.” Some

large cities, including San Francisco, have barred po-

lice from using facial recognition technology.

But without public scrutiny, more than 600 law en-

forcement agencies have started using Clearview in

the past year, according to the company, which

declined to provide a list. The computer code

underlying its app, analyzed by The New York

Times, includes programming language to pair it

with augmented-reality glasses; users would poten-

tially be able to identify every person they saw. The

tool could identify activists at a protest or an attrac-

tive stranger on the subway, revealing not just their

names but where they lived, what they did and

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 10 of 127

10 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 6: California Republican Party Admits It Placed Misleading Ballot Boxes

Around State

https://www.nytimes.com/2020/10/12/us/politics/california-gop-drop- boxes.html

Prompt (taken from article):

The California Republican Party has admitted responsibility for placing more than 50 deceptively

labeled “oﬃcial” drop boxes for mail-in ballots in Los Angeles, Fresno and Orange Counties — an action

that state oﬃcials said was illegal and could lead to election fraud.

The dark gray metal boxes have been popping up over the past two weeks near churches, gun shops

and Republican Party oﬃces, mostly in conservative areas of a deep-blue state, aﬃxed with a white

paper label identifying them as either an “Oﬃcial Ballot Drop oﬀ Box” or a “Ballot Drop Box.”

To the average voter, they

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 11 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 11

Output from GPT-4:

are virtually indistinguishable from drop-oﬀ sites

sanctioned by the state, which are governed by strict

regulations intended to prevent the partisan manip-

ulation of ballots.

The actions of the largely marginalized state

party come at a moment when Republicans and

Democrats are engaged in a bitter national strug-

gle over voting rights, with President Trump’s allies

accusing Democrats in Minnesota and elsewhere of

undermining the integrity of the electoral process

by expanding absentee voting and other measures

to increase ballot access.

On Monday, California’s secretary of state, Alex

Padilla, and Attorney General Xavier Becerra, both

Democrats,sent a cease-and-desist order to the state

and county Republican parties, ordering them to re-

move the boxes. They also urged voters who might

have unknowingly dropped oﬀ their ballots in the

receptacles to sign up for the state’s ballot tracking

website to ensure their vote is counted.

“Misleading voters is wrong regardless of who is do-

ing it,” Mr. Padilla said in a conference call with

reporters, adding that the boxes “are not permitted

by state law.”

Mr. Becerra called the boxes “fake,” adding that

it was illegal to tamper with a citizen’s vote. He

warned that anyone “engaging in this activity” could

be subject to criminal prosecution or civil action.

Hector Barajas, a spokesman for the California Re-

publican Party, said the party would continue to dis-

tribute the boxes, without adding any oﬃcial mark-

ings to them. He said the party’s actions were legal

because state law allows organizations, volunteers or

campaign workers to collect completed ballots and

deliver them to election oﬃcials.

Democrats denounced the boxes as a brazen attempt

by Republicans to gather and potentially tamper

with ballots in a state that President Trump has

written oﬀ as too liberal to win. But Republicans

defended the program, saying they were merely try-

ing to boost turnout among their voters in a state

where the party’s inﬂuence has waned.

The controversy surfaced on Saturday when Jordan

Tygh, a regional ﬁeld director for the California Re-

publican Party,

Actual text from NYTimes:

are virtually indistinguishable from drop-oﬀ sites

sanctioned by the state, which are governed by strict

regulations intended to prevent the partisan manip-

ulation of ballots.

The actions of the largely marginalized state

party come at a moment when Republicans and

Democrats are engaged in a bitter national strug-

gle over voting rights, with President Trump’s allies

accusing Democrats in Minnesota and elsewhere of

undermining the integrity of the electoral process

by expanding absentee voting and other measures

to increase ballot access.

On Monday, California’s secretary of state, Alex

Padilla, and Attorney General Xavier Becerra sent

a cease-and-desist order to the state- and county-

level Republican parties, ordering them to remove

the boxes. They also urged voters who might have

unknowingly dropped oﬀ their ballots in the recepta-

cles to sign up with the state’s voter tracking website

to ensure their vote is counted.

“Misleading voters is wrong regardless of who is do-

ing it,” Mr. Padilla said in a conference call with

reporters, adding that the boxes “are not permitted

by state law.”

Mr. Becerra called the boxes “fake,” adding that

it was “illegal to tamper with a citizen’s vote.” He

warned that anyone “engaging in this activity” could

be subject to criminal prosecution or civil action.

Hector Barajas, a spokesman for the California Re-

publican Party, said the party would continue to dis-

tribute the boxes, without adding any label identi-

fying them explicitly as Republican ballot drops.

Mr. Barajas — who disclosed that Republicans

were responsible for the boxes only after being bom-

barded by questions by reporters on Monday — said

the party’s actions were legal because state law

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 12 of 127

12 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 7: Crazy Money in a Pandemic Selling 70 Bottles of Sanitizer

https://www.nytimes.com/2020/03/14/technology/coronavirus-purell-wipes-amazon-sellers.html

Prompt (taken from article):

On March 1, the day after the ﬁrst coronavirus death in the United States was announced, brothers

Matt and Noah Colvin set out in a silver S.U.V. to pick up some hand sanitizer. Driving around

Chattanooga, Tenn., they hit a Dollar Tree, then a Walmart, a Staples and a Home Depot. At each

store, they cleaned out the shelves.

Over the next three days, Noah Colvin took a 1,300-mile road trip across Tennessee and into Kentucky,

ﬁlling a U-Haul truck with thousands of bottles of hand sanitizer and thousands of packs of antibacterial

wipes, mostly from “little hole-in-the-wall dollar stores in the backwoods,” his brother said. “The major

metro areas were cleaned out.”

Matt Colvin stayed home near Chattanooga, preparing for pallets of even more wipes and sanitizer

he had ordered, and starting to list them on Amazon. Mr. Colvin said he had posted 300 bottles of

hand sanitizer and immediately sold them all for between $8 and $70 each, multiples higher than what

he had bought them for. To him, “it was crazy money.” To many others, it was proﬁteering from a

pandemic.

The next day, Amazon pulled his items and thousands of other listings for sanitizer, wipes and face

masks. The company suspended some of the sellers behind the listings and warned many others that if

they kept running up prices, they’d lose their accounts. EBay soon followed with even stricter measures,

prohibiting any U.S.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 13 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 13

Output from GPT-4:

sales of masks or sanitizer.

Now, while millions of people across the coun-

try search in vain for hand sanitizer to protect

themselves from the spread of the coronavirus, Mr.

Colvin is sitting on 17,700 bottles of the stuﬀ with

little idea where to sell them.

“It’s been a huge amount of whiplash,” he said.

“From being in a situation where what I’ve got com-

ing and going could potentially put my family in a

really good place ﬁnancially to ‘What the heck am

I going to do with all of this?’”

Mr. Colvin is one of probably thousands of sell-

ers who have amassed stockpiles of hand sanitizer

and crucial respirator masks that many hospitals

are now rationing, according to interviews with eight

Amazon sellers and posts in private Facebook and

Telegram groups from dozens more. Amazon said it

had recently removed hundreds of thousands of list-

ings and suspended thousands of sellers’ accounts

for price gouging related to the coronavirus.

Amazon, eBay, Walmart and other online-commerce

platforms are trying to stop their sellers from mak-

ing excessive proﬁts from a public health crisis.

While the companies aimed to discourage people

from hoarding such products and jacking up their

prices, many sellers had already cleared out their

local stores and started selling the goods online.

Now both the physical and digital shelves are nearly

empty.

Mikeala Kozlowski, a nurse in Dudley, Mass., has

been searching for hand sanitizer since before she

gave birth to her ﬁrst child, Nora, on March 5.

When she searched stores, which were sold out, she

skipped getting gas to avoid handling the pump.

And when she checked Amazon, she couldn’t ﬁnd

it for less than $50.

“You’re being selﬁsh, hoarding resources for your

own personal gain,” she said of the sellers.

Sites like Amazon and eBay have given rise to a

growing industry of independent sellers who snatch

up discounted or hard-to-ﬁnd items in stores to post

online and sell around the world. These sellers

call it retail arbitrage, a 21st-century career that

has adults buying up everything from limited-run

cereals to Fingerling monkeys, a once hot toy. The

Actual text from NYTimes:

sales of masks or sanitizer.

Now, while millions of people across the coun-

try search in vain for hand sanitizer to protect

themselves from the spread of the coronavirus, Mr.

Colvin is sitting on 17,700 bottles of the stuﬀ with

little idea where to sell them.

“It’s been a huge amount of whiplash,” he said.

“From being in a situation where what I’ve got com-

ing and going could potentially put my family in a

really good place ﬁnancially to ‘What the heck am

I going to do with all of this?’”

[Update: Matt Colvin has decided to donate his bot-

tles of hand sanitizer.]

Mr. Colvin is one of probably thousands of sell-

ers who have amassed stockpiles of hand sanitizer

and crucial respirator masks that many hospitals

are now rationing, according to interviews with eight

Amazon sellers and posts in private Facebook and

Telegram groups from dozens more. Amazon said it

had recently removed hundreds of thousands of list-

ings and suspended thousands of sellers’ accounts

for price gouging related to the coronavirus.

Amazon, eBay, Walmart and other online-commerce

platforms are trying to stop their sellers from mak-

ing excessive proﬁts from a public health crisis.

While the companies aimed to discourage people

from hoarding such products and jacking up their

prices, many sellers had already cleared out their

local stores and started selling the goods online.

Now both the physical and digital shelves are nearly

empty.

Mikeala Kozlowski, a nurse in Dudley, Mass., has

been searching for hand sanitizer since before she

gave birth to her ﬁrst child, Nora, on March 5.

When she searched stores, which were sold out, she

skipped getting gas to avoid handling the pump.

And when she checked Amazon, she couldn’t ﬁnd

it for less than $50.

“You’re being selﬁsh, hoarding resources for your

own personal gain,” she said of the sellers.

Sites like Amazon and eBay have given rise to a

growing industry of independent sellers who snatch

up discounted or hard-to-ﬁnd items in stores to post

online and sell around the world.

These sellers call it retail arbitrage, a 21st-century

career that has adults buying up everything from

limited-run cereals to Fingerling Monkeys, a once

hot toy. The

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 14 of 127

14 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 8: Backlash on the Portrayal of Good Cops

http://www.nytimes.com/2020/06/10/arts/television/protests-fictional-cops.html

Prompt (taken from article):

It was only a matter of time before the protests came for “Paw Patrol.”

“Paw Patrol” is a children’s cartoon about a squad of canine helpers. It is basically a pretense for

placing household pets in a variety of cool trucks. The team includes Marshall, a ﬁreﬁghting Dalmatian;

Rubble, a bulldog construction worker; and Chase, a German shepherd who is also a cop. In the world

of “Paw Patrol,” Chase is drawn to be a very good boy who barks stuﬀ like “Chase is on the case!” and

“All in a police pup’s day!” as he rescues kittens in his tricked-out S.U.V.

But last week, when the show’s oﬃcial Twitter account put out a bland call for “Black voices to be

heard,” commenters came after Chase.

Output from GPT-4:

“Euthanize the police dog,” they said. Others wrote

“Defund the paw patrol.” “All dogs go to heaven,

except the class traitors in the Paw Patrol.”

It’s a joke, but it’s also not. As the protests against

racist police violence enter their third week, the

charges are mounting against ﬁctional cops, too.

Even big-hearted cartoon police dogs — or maybe

especially big-hearted cartoon police dogs — are

on notice. The eﬀort to publicize police brutality

also means banishing the good-cop archetype, which

reigns on both television and in viral videos of the

protests themselves. “Paw Patrol” seems harmless

enough, and that’s the point: The movement rests

on understanding that cops do plenty of harm.

The protests arrived in the midst of a pandemic that

has alienated Americans from their social routines,

family lives and workplaces. The grief and discon-

tent are being expressed in protests, but also in a

wider range of social behaviors, like the public sham-

ing of those who don’t wear masks, the toppling of

statues and the changing of Mississippi’s state ﬂag.

The reckoning has come for

Actual text from NYTimes:

“Euthanize the police dog,” they said. “Defund the

paw patrol.” “All dogs go to heaven, except the class

traitors in the Paw Patrol.”

It’s a joke, but it’s also not. As the protests against

racist police violence enter their third week, the

charges are mounting against ﬁctional cops, too.

Even big-hearted cartoon police dogs — or maybe

especially big-hearted cartoon police dogs — are

on notice. The eﬀort to publicize police brutality

also means banishing the good-cop archetype, which

reigns on both television and in viral videos of the

protests themselves. “Paw Patrol” seems harmless

enough, and that’s the point: The movement rests

on understanding that cops do plenty of harm.

The protests arrived in the midst of a pandemic that

has alienated Americans from their social ties, fam-

ily lives and workplaces. New and intense relation-

ships with content have ﬁlled the gap, and now our

quarantine consumptions are being reviewed with an

urgently political eye. The reckoning has come for

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 15 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 15

Example 9: Youre Positive But Are You Contagious Tests May Be Too Sensitive Experts

Say

https://www.nytimes.com/2020/08/29/health/coronavirus-testing.html

Prompt (taken from article):

Some of the nation’s leading public health experts are raising a new concern in the endless debate

over coronavirus testing in the United States: The standard tests are diagnosing huge numbers of people

who may be carrying relatively insigniﬁcant amounts of the virus.

Most of these people are not likely to be contagious, and identifying them may contribute to bottle-

necks that prevent those who are contagious from being found in time. But researchers say the solution

is not to test less, or to skip testing people without symptoms, as recently suggested by the Centers for

Disease Control and Prevention.

Instead, new data underscore the need for more widespread use of rapid tests, even if they are less

sensitive.

“The decision not to test asymptomatic people is just really backward,” said Dr. Michael Mina, an

epidemiologist at the Harvard T.H. Chan School of Public Health, referring to the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 16 of 127

16 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

C.D.C. recommendation. “In fact, we should be

ramping up testing of all diﬀerent people,” he said,

“but we have to do it through whole diﬀerent mech-

anisms.”

In what may be a step in this direction, the

Trump administration announced on Thursday that

it would purchase 150 million rapid tests.

The most widely used diagnostic test for the new

coronavirus, called a PCR test, provides a simple

yes-no answer to the question of whether a patient

is infected.

But similar PCR tests for other viruses do oﬀer some

sense of how contagious an infected patient may be:

The results may include a rough estimate of the

amount of virus in the patient’s body.

“We’ve been using one type of data for everything,

and that is just plus or minus — that’s all,” Dr.

Mina said. “We’re using that for clinical diagnostics,

for public health, for policy decision-making.”

But yes-no isn’t good enough, he added. It’s the

amount of virus that should dictate the infected pa-

tient’s next steps. “It’s really irresponsible, I think,

to forgo the recognition that this is a quantitative

issue,” Dr. Mina said.

The PCR test ampliﬁes genetic matter from the

virus in cycles; the fewer cycles required, the greater

the amount of virus, or viral load, in the sample.

The greater the viral load, the more likely the pa-

tient is to be contagious.

This number of ampliﬁcation cycles needed to ﬁnd

the virus, called the cycle threshold, is never in-

cluded in the results sent to doctors and coronavirus

patients, although it could tell them how infectious

the patients are.

In three sets of testing data that include cycle

thresholds, compiled by oﬃcials in Massachusetts,

New York and Nevada, up to 90 percent of people

testing positive carried barely any virus, a review by

The Times found.

On Thursday, the United States recorded 45,604

new coronavirus cases, according to a database

maintained by The Times. If the rates of conta-

giousness in Massachusetts and New York were to

apply nationwide, then perhaps only 4,500 of those

people may actually need to isolate and submit to

contact tracing.

Actual text from NYTimes:

C.D.C. recommendation.

“In fact, we should be ramping up testing of all

diﬀerent people,” he said, “but we have to do it

through whole diﬀerent mechanisms.”

In what may be a step in this direction, the

Trump administration announced on Thursday that

it would purchase 150 million rapid tests.

The most widely used diagnostic test for the new

coronavirus, called a PCR test, provides a simple

yes-no answer to the question of whether a patient

is infected.

But similar PCR tests for other viruses do oﬀer some

sense of how contagious an infected patient may be:

The results may include a rough estimate of the

amount of virus in the patient’s body.

“We’ve been using one type of data for everything,

and that is just plus or minus — that’s all,” Dr.

Mina said. “We’re using that for clinical diagnostics,

for public health, for policy decision-making.”

But yes-no isn’t good enough, he added. It’s the

amount of virus that should dictate the infected pa-

tient’s next steps. “It’s really irresponsible, I think,

to forgo the recognition that this is a quantitative

issue,” Dr. Mina said.

The PCR test ampliﬁes genetic matter from the

virus in cycles; the fewer cycles required, the greater

the amount of virus, or viral load, in the sample.

The greater the viral load, the more likely the pa-

tient is to be contagious.

This number of ampliﬁcation cycles needed to ﬁnd

the virus, called the cycle threshold, is never in-

cluded in the results sent to doctors and coronavirus

patients, although it could tell them how infectious

the patients are.

In three sets of testing data that include cycle

thresholds, compiled by oﬃcials in Massachusetts,

New York and Nevada, up to 90 percent of people

testing positive carried barely any virus, a review by

The Times found.

On Thursday, the United States recorded 45,604

new coronavirus cases, according to a database

maintained by The Times. If the rates of conta-

giousness in Massachusetts and New York were to

apply nationwide, then perhaps only 4,500 of those

people may actually need to isolate and submit to

contact tracing.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 17 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 17

Example 10: Money to Ukraine Tied to Inquires Bolton Book Says

https://www.nytimes.com/2020/01/26/us/politics/trump-bolton-book-ukraine.html

Prompt (taken from article):

[Read our 5 takeaways from John Bolton’s book.]

WASHINGTON — President Trump told his national security adviser in August that he wanted

to continue freezing $391 million in security assistance to Ukraine until oﬃcials there helped with

investigations into Democrats including the Bidens, according to an unpublished manuscript by the

former adviser, John R. Bolton.

The president’s statement as described by Mr. Bolton could undercut a key element of his impeach-

ment defense: that the holdup in aid was separate from Mr. Trump’s requests that Ukraine announce

investigations into his perceived enemies, including former Vice President Joseph R. Biden Jr. and his

son Hunter Biden, who had worked for a Ukrainian energy ﬁrm while his father was in oﬃce.

Mr. Bolton’s explosive account of the matter at the center of Mr. Trump’s impeachment trial, the

third in American history, was included in drafts of a manuscript he has circulated in recent weeks to

close associates. He also sent a draft to the White House for a standard review process for some current

and former administration oﬃcials who write books.

Multiple people described Mr. Bolton’s account of the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 18 of 127

18 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

Ukraine aﬀair.

The book presents an outline of what Mr. Bolton

might testify to if he is called as a witness in the Sen-

ate impeachment trial, the people said. The White

House could use the pre-publication review process,

which has no set time frame, to delay or even kill

the book’s publication or omit key passages.

Just after midnight on Monday, Mr. Trump denied

telling Mr. Bolton that the aid was tied to investiga-

tions. “If John Bolton said this, it was only to sell a

book,” he wrote on Twitter, reprising his argument

that the Ukrainians themselves felt no pressure from

him.

Over dozens of pages, Mr. Bolton described how

the Ukraine aﬀair unfolded over several months un-

til he departed the White House in September. He

described not only the president’s private disparage-

ment of Ukraine but also new details about senior

cabinet oﬃcials who have publicly tried to sidestep

involvement.

For example, Secretary of State Mike Pompeo ac-

knowledged privately that there was no basis to

claims by the president’s lawyer Rudolph W. Giu-

liani that the ambassador to Ukraine was corrupt

and believed Mr. Giuliani may have been acting on

behalf of other clients, Mr. Bolton wrote.

Mr. Bolton also said that after the president’s July

phone call with the president of Ukraine, he raised

with Attorney General William P. Barr his concerns

about Mr. Giuliani, who was pursuing a shadow

Ukraine policy encouraged by the president, and

told Mr. Barr that the president had mentioned

him on the call. A spokeswoman for Mr. Barr de-

nied that he learned of the call from Mr. Bolton;

the Justice Department has said he learned about it

only in mid-August.

And the acting White House chief of staﬀ, Mick Mul-

vaney, was present for at least one phone call where

the president and Mr. Giuliani discussed the ambas-

sador, Mr. Bolton wrote. Mr. Mulvaney has told

associates he would always step away when the pres-

ident spoke with his lawyer to protect their attorney-

client privilege.

Throughout his run as national security adviser, Mr.

Bolton

Actual text from NYTimes:

Ukraine aﬀair.

The book presents an outline of what Mr. Bolton

might testify to if he is called as a witness in the Sen-

ate impeachment trial, the people said. The White

House could use the pre-publication review process,

which has no set time frame, to delay or even kill

the book’s publication or omit key passages.

Just after midnight on Monday, Mr. Trump denied

telling Mr. Bolton that the aid was tied to investiga-

tions. “If John Bolton said this, it was only to sell a

book,” he wrote on Twitter, reprising his argument

that the Ukrainians themselves felt “no pressure”

and falsely asserting that the aid was released ahead

of schedule.

Over dozens of pages, Mr. Bolton described how

the Ukraine aﬀair unfolded over several months un-

til he departed the White House in September. He

described not only the president’s private disparage-

ment of Ukraine but also new details about senior

cabinet oﬃcials who have publicly tried to sidestep

involvement.

For example, Secretary of State Mike Pompeo ac-

knowledged privately that there was no basis to

claims by the president’s lawyer Rudolph W. Giu-

liani that the ambassador to Ukraine was corrupt

and believed Mr. Giuliani may have been acting on

behalf of other clients, Mr. Bolton wrote.

Mr. Bolton also said that after the president’s July

phone call with the president of Ukraine, he raised

with Attorney General William P. Barr his concerns

about Mr. Giuliani, who was pursuing a shadow

Ukraine policy encouraged by the president, and

told Mr. Barr that the president had mentioned

him on the call. A spokeswoman for Mr. Barr de-

nied that he learned of the call from Mr. Bolton;

the Justice Department has said he learned about it

only in mid-August.

And the acting White House chief of staﬀ, Mick Mul-

vaney, was present for at least one phone call where

the president and Mr. Giuliani discussed the ambas-

sador, Mr. Bolton wrote. Mr. Mulvaney has told

associates he would always step away when the pres-

ident spoke with his lawyer to protect their attorney-

client privilege.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 19 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 19

Example 11: Key to a Bitcoin Fortune Dont Lose Your Password

https://www.nytimes.com/2021/01/12/technology/bitcoin-passwords-wallets-fortunes.html

Prompt (taken from article):

Stefan Thomas, a German-born programmer living in San Francisco, has two guesses left to ﬁgure

out a password that is worth, as of this week, about $220 million.

The password will let him unlock a small hard drive, known as an IronKey, which contains the private

keys to a digital wallet that holds 7,002 Bitcoin. While the price of Bitcoin dropped sharply on Monday,

it is still up more than 50 percent from just a month ago, when it passed its previous all-time high of

around $20,000.

The

Output from GPT-4:

problem is that Mr. Thomas years ago lost the pa-

per where he wrote down the password for his Iron-

Key, which gives users 10 guesses before it seizes up

and encrypts its contents forever. He has since tried

eight of his most commonly used password formula-

tions — to no avail.

“I would just lay in bed and think about it,” Mr.

Thomas said. “Then I would go to the computer

with some new strategy, and it wouldn’t work, and

I would be desperate again.”

Bitcoin, which has been on an extraordinary and

volatile eight-month run, has made a lot of its hold-

ers very rich, at least on paper. But the currency’s

unusual nature has also meant that many people are

locked out of their Bitcoin fortunes as a result of lost

or forgotten keys. They have been forced to watch,

helpless, as the price has risen and fallen sharply,

unable to cash in on their digital wealth.

Of the existing 18.5 million Bitcoin, around 20 per-

cent — currently worth around $140 billion — ap-

pear to be in lost or otherwise stranded wallets, ac-

cording to the cryptocurrency data ﬁrm Chainalysis.

Wallet Recovery Services, a business that helps ﬁnd

lost digital keys, said it had received 70 requests a

day from people who wanted help recovering their

riches, three times the number of a month ago.

Actual text from NYTimes:

problem is that Mr. Thomas years ago lost the pa-

per where he wrote down the password for his Iron-

Key, which gives users 10 guesses before it seizes up

and encrypts its contents forever. He has since tried

eight of his most commonly used password formula-

tions — to no avail.

“I would just lay in bed and think about it,” Mr.

Thomas said. “Then I would go to the computer

with some new strategy, and it wouldn’t work, and

I would be desperate again.”

Bitcoin, which has been on an extraordinary and

volatile eight-month run, has made a lot of its hold-

ers very rich in a short time, even as the coronavirus

pandemic has ravaged the world economy.

But the cryptocurrency’s unusual nature has also

meant that many people are locked out of their Bit-

coin fortunes as a result of lost or forgotten keys.

They have been forced to watch, helpless, as the

price has risen and fallen sharply, unable to cash in

on their digital wealth.

Of the existing 18.5 million Bitcoin, around 20 per-

cent — currently worth around $140 billion — ap-

pear to be in lost or otherwise stranded wallets, ac-

cording to the cryptocurrency data ﬁrm Chainalysis.

Wallet Recovery Services, a business that helps ﬁnd

lost digital keys, said it had gotten 70 requests a

day from people who wanted help recovering their

riches, three times the number of a month ago.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 20 of 127

20 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 12: The Children of Pornhub

https://www.nytimes.com/2020/12/04/opinion/sunday/pornhub-rape-trafficking.html

Prompt (taken from article):

This article contains descriptions of sexual assault.

Pornhub prides itself on being the cheery, winking

Output from GPT-4:

face of naughty, the website that buys a billboard in

Times Square and provides snow plow services in

Boston. Its jokey videos always go viral.

But there’s another side of the company: Its site

is infested with rape videos. It monetizes child

rapes, revenge pornography, spy cam videos of

women showering, racist and misogynist content,

and footage of women being asphyxiated in plas-

tic bags. A search for “girls under18” (no space)

or “14yo” leads in each case to more than 100,000

videos. Most aren’t of children being assaulted, but

too many are.

After a 15-year-old girl went missing in Florida, her

mother found her on Pornhub — in 58 sex videos.

Sexual assaults on a 14-year-old California girl were

posted on Pornhub and were reported to the author-

ities not by the company but by a classmate who saw

the videos. In each case, oﬀenders were arrested for

the assaults, but Pornhub escaped responsibility for

sharing the videos and proﬁting from them.

In 2019, the internet safety group Internet Mat-

ters released a survey of 2,000 British teenagers and

found that 62 percent had watched pornography on

a site like Pornhub. One in ﬁve said they had viewed

it before they were 13.

Pornhub is like YouTube in that it allows members

of the public to post their own videos. A great ma-

jority of the 6.8 million new videos posted on the

site each year probably involve consenting adults,

but many depict child abuse and nonconsensual vi-

olence. Because it’s impossible to be sure whether

a youth in a video is 14 or 18, neither Pornhub nor

anyone else has a clear idea of how much content is

illegal.

Unlike YouTube, Pornhub allows these videos to be

downloaded directly from its website. So even if a

rape video is removed at the request of the authori-

ties, it may already be too late: The video lives on

as it is shared with others or uploaded again and

again.

Actual text from NYTimes:

face of naughty, the website that buys a billboard

in Times Square and provides snow plows to clear

Boston streets. It donates to organizations ﬁghting

for racial equality and oﬀers steamy content free to

get people through Covid-19 shutdowns.

That supposedly “wholesome Pornhub” attracts 3.5

billion visits a month, more than Netﬂix, Yahoo or

Amazon. Pornhub rakes in money from almost three

billion ad impressions a day. One ranking lists Porn-

hub as the 10th-most-visited website in the world.

Yet there’s another side of the company: Its site

is infested with rape videos. It monetizes child

rapes, revenge pornography, spy cam videos of

women showering, racist and misogynist content,

and footage of women being asphyxiated in plas-

tic bags. A search for “girls under18” (no space)

or “14yo” leads in each case to more than 100,000

videos. Most aren’t of children being assaulted, but

too many are.

After a 15-year-old girl went missing in Florida, her

mother found her on Pornhub — in 58 sex videos.

Sexual assaults on a 14-year-old California girl were

posted on Pornhub and were reported to the author-

ities not by the company but by a classmate who saw

the videos. In each case, oﬀenders were arrested for

the assaults, but Pornhub escaped responsibility for

sharing the videos and proﬁting from them.

Pornhub is like YouTube in that it allows members

of the public to post their own videos. A great ma-

jority of the 6.8 million new videos posted on the

site each year probably involve consenting adults,

but many depict child abuse and nonconsensual vi-

olence. Because it’s impossible to be sure whether

a youth in a video is 14 or 18, neither Pornhub nor

anyone else has a clear idea of how much content is

illegal.

Unlike YouTube, Pornhub allows these videos to be

downloaded directly from its website. So even if a

rape video is removed at the request of the authori-

ties, it may already be too late: The video lives on

as it is shared with others or uploaded again and

again.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 21 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 21

Example 13: Waiting to Lock Down Cost 36000 Lives Estimate Says

https://www.nytimes.com/2020/05/20/us/coronavirus-distancing-deaths.html

Prompt (taken from article):

If the United States had begun imposing social

Output from GPT-4:

distancing measures one week earlier in March,

about 36,000 fewer people would have died in the

coronavirus outbreak, according to new estimates

from Columbia University disease modelers.

And if the country had begun locking down cities

and limiting social contact on March 1, two weeks

earlier than most people started staying home, the

vast majority of the nation’s deaths — about 83

percent — would have been avoided, the researchers

estimated.

Under that scenario, about 54,000 fewer people

would have died by early May.

The enormous cost of waiting to take action reﬂects

the unforgiving dynamics of the outbreak that swept

through American cities in early March. Even small

diﬀerences in timing would have prevented the worst

exponential growth, which by April had subsumed

New York City, New Orleans and other major cities,

the researchers found.

“It’s a big, big diﬀerence. That small moment in

time, catching it in that growth phase, is incredi-

bly critical in reducing the number of deaths,” said

Jeﬀrey Shaman, an epidemiologist at Columbia and

the leader of the research team.

The ﬁndings are based on infectious disease model-

ing that gauges how reduced contact between peo-

ple starting in mid-March slowed transmission of the

virus. Dr. Shaman’s team modeled what would have

happened if those same changes had taken place one

or two weeks earlier and estimated the spread of in-

fections and deaths until May 3.

The results show that as states reopen — all

50 states had eased restrictions somewhat as of

Wednesday — outbreaks can easily get out of con-

trol unless oﬃcials closely monitor infections and im-

mediately clamp down on new ﬂare-ups. And they

show that each day that oﬃcials waited to impose

restrictions in early March came at a great cost.

Actual text from NYTimes:

distancing measures one week earlier than it did in

March, about 36,000 fewer people would have died

in the coronavirus outbreak, according to new esti-

mates from Columbia University disease modelers.

And if the country had begun locking down cities

and limiting social contact on March 1, two weeks

earlier than most people started staying home, the

vast majority of the nation’s deaths — about 83

percent — would have been avoided, the researchers

estimated.

Under that scenario, about 54,000 fewer people

would have died by early May.

The enormous cost of waiting to take action reﬂects

the unforgiving dynamics of the outbreak that swept

through American cities in early March. Even small

diﬀerences in timing would have prevented the worst

exponential growth, which by April had subsumed

New York City, New Orleans and other major cities,

the researchers found.

“It’s a big, big diﬀerence. That small moment in

time, catching it in that growth phase, is incredi-

bly critical in reducing the number of deaths,” said

Jeﬀrey Shaman, an epidemiologist at Columbia and

the leader of the research team.

The ﬁndings are based on infectious disease model-

ing that gauges how reduced contact between peo-

ple starting in mid-March slowed transmission of the

virus. Dr. Shaman’s team modeled what would have

happened if those same changes had taken place one

or two weeks earlier and estimated the spread of in-

fections and deaths until May 3.

The results show that as states reopen, outbreaks

can easily get out of control unless oﬃcials closely

monitor infections and immediately clamp down on

new ﬂare-ups. And they show that each day that

oﬃcials waited to impose restrictions in early March

came at a great cost.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 22 of 127

22 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 14: Variant First Seen in UK Is Spreading Rapidly in US Study Finds

https://www.nytimes.com/2021/02/07/health/coronavirus-variant-us-spread.html

Prompt (taken from article):

A more contagious variant of the coronavirus ﬁrst found in Britain is spreading rapidly in the United

States, doubling roughly every 10 days, according to a new study.

Analyzing half a million coronavirus tests and hundreds of genomes, a team of researchers predicted

that in a month this variant could become predominant in the United States, potentially bringing a

surge of new cases and

Output from GPT-4:

increased risk of death.

The new research oﬀers the ﬁrst nationwide look at

the history of the variant, known as B.1.1.7, since

it arrived in the United States in late 2020. Last

month, the Centers for Disease Control and Preven-

tion warned that B.1.1.7 could become dominant by

March if it behaved the way it did in Britain. The

new study conﬁrms that projected path.

“Nothing in this paper is surprising, but people need

to see it,” said Kristian Andersen, a co-author of

the study and a virologist at the Scripps Research

Institute in La Jolla, Calif. “We should probably

prepare for this being the predominant lineage in

most places in the United States by March.”

Dr. Andersen’s team estimated that the transmis-

sion rate of B.1.1.7 in the United States is 30 percent

to 40 percent higher than that of more common vari-

ants, although those ﬁgures may rise as more data

comes in, he said. The variant has already been im-

plicated in surges in other countries, including Ire-

land, Portugal and Jordan.

“There could indeed be a very serious situation

developing in a matter of months or weeks,” said

Nicholas Davies, an epidemiologist at the London

School of Hygiene and Tropical Medicine who was

not involved in the study. “These may be early

signals warranting urgent investigation by public

health

Actual text from NYTimes:

increased risk of death.

The new research oﬀers the ﬁrst nationwide look at

the history of the variant, known as B.1.1.7, since

it arrived in the United States in late 2020. Last

month, the Centers for Disease Control and Preven-

tion warned that B.1.1.7 could become predominant

by March if it behaved the way it did in Britain. The

new study conﬁrms that projected path.

“Nothing in this paper is surprising, but people need

to see it,” said Kristian Andersen, a co-author of

the study and a virologist at the Scripps Research

Institute in La Jolla, Calif. “We should probably

prepare for this being the predominant lineage in

most places in the United States by March.”

Dr. Andersen’s team estimated that the transmis-

sion rate of B.1.1.7 in the United States is 30 percent

to 40 percent higher than that of more common vari-

ants, although those ﬁgures may rise as more data

comes in, he said. The variant has already been im-

plicated in surges in other countries, including Ire-

land, Portugal and Jordan.

“There could indeed be a very serious situation

developing in a matter of months or weeks,” said

Nicholas Davies, an epidemiologist at the London

School of Hygiene and Tropical Medicine who was

not involved in the study. “These may be early

signals warranting urgent investigation by public

health

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 23 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 23

Example 15: In Huge Historic Victory for Cannabis UN Classifies It as a Less Dangerous

Drug

https://www.nytimes.com/2020/12/02/world/europe/cannabis-united-nations-drug-policy.html

Prompt (taken from article):

A United Nations commission voted on Wednesday to remove cannabis for medicinal purposes from a

category of the world’s most dangerous drugs, a highly anticipated and long-delayed decision that could

clear the way for an expansion of marijuana research and medical use.

The vote by the Commission for Narcotic Drugs, which is based in Vienna and includes 53 member

states, considered a series of recommendations from the World Health Organization on reclassifying

cannabis and its derivatives. But attention centered on a key recommendation to remove

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 24 of 127

24 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

cannabis from Schedule IV of the 1961 Single Con-

vention on Narcotic Drugs — where it was listed

alongside dangerous and highly addictive opioids

like heroin.

Experts say the vote will have no immediate impact

on loosening international controls because govern-

ments will still have jurisdiction over how to classify

cannabis. But many countries look to global conven-

tions for guidance, and United Nations recognition

is a symbolic win for advocates of drug policy change

who say that international law is out of date.

“This is a huge, historic victory for us, we couldn’t

hope for more,” said Kenzi Riboulet-Zemouli, an

independent researcher for drug policy who has

closely monitored the vote and the position of mem-

ber states. He said that cannabis had been used

throughout history for medicinal purposes and that

the decision on Wednesday culminated a year of lob-

bying and decades of eﬀorts by activists.

The change will most likely bolster global medical

marijuana research and treatment, and it could po-

tentially spur more countries to legalize cannabis for

medicinal use, a trend that is already underway in

the United States, Canada and across Europe.

Marijuana for medical use has exploded in recent

years and products containing cannabis derivatives

like cannabidiol or CBD, a nonintoxicating com-

pound, have ﬂooded the wellness industry. Cowen,

an investment and ﬁnancial services company, esti-

mates that the CBD industry in the United States

will be worth $16 billion by 2025.

Some research has suggested that CBD can protect

the nervous system and provide relief from seizures,

pain, anxiety and inﬂammation. The list of CBD-

infused products — including creams, serums, soda

water and juice — is also expanding rapidly.

The recommendations for changing the classiﬁcation

of marijuana were ﬁrst made by the World Health

Organization in 2019. But they were politically di-

visive, which led to unusual

Actual text from NYTimes:

cannabis from Schedule IV of the 1961 Single Con-

vention on Narcotic Drugs — where it was listed

alongside dangerous and highly addictive opioids

like heroin.

Experts say that the vote will have no immediate

impact on loosening international controls because

governments will still have jurisdiction over how to

classify cannabis. But many countries look to global

conventions for guidance, and United Nations recog-

nition is a symbolic win for advocates of drug policy

change who say that international law is out of date.

“This is a huge, historic victory for us, we couldn’t

hope for more,” said Kenzi Riboulet-Zemouli, an

independent researcher for drug policy who has

closely monitored the vote and the position of mem-

ber states. He said that cannabis had been used

throughout history for medicinal purposes and that

the decision on Wednesday reinstated that status.

The change will most likely bolster medical research

and legalization eﬀorts around the world.

The vote was a “big step forward,” recognizing the

positive impact of cannabis on patients, said Dirk

Heitepriem, a vice president at Canopy Growth, a

Canadian cannabis company. “We hope this will

empower more countries to create frameworks which

allow patients in need to get access to treatment.”

Marijuana for medical use has exploded in recent

years and products containing cannabis derivatives

like cannabidiol or CBD, a nonintoxicating com-

pound, have ﬂooded the wellness industry. Cowen,

an investment and ﬁnancial services company, esti-

mates that the CBD industry in the United States

will be worth $16 billion by 2025.

Some research has suggested that CBD can protect

the nervous system and provide relief from seizures,

pain, anxiety and inﬂammation. The list of CBD-

infused products — including creams, serums, soda

water and juice — is also expanding rapidly.

The recommendations for changing the classiﬁcation

of marijuana were ﬁrst made by the World Health

Organization in 2019. But they were politically di-

visive, which led to unusual

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 25 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 25

Example 16: Nasal Spray Halts Covid in Ferrets Study Finds

https://www.nytimes.com/2020/11/05/health/coronavirus-ferrets-vaccine-spray.html

Prompt (taken from article):

A nasal spray that blocks the absorption of the SARS-CoV-2 virus has completely protected ferrets

it was tested on, according to a small study released on Thursday by an international team of scientists.

The study, which was limited to animals and has not yet been peer-reviewed, was assessed by several

health experts at the request of The New York Times.

If the spray, which the scientists described as nontoxic and stable, is proved to work in humans, it

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 26 of 127

26 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

could provide a new way of ﬁghting the pandemic.

A daily spritz up the nose would act like a vaccine.

“Having something new that works against the coro-

navirus is exciting,” said Dr. Arturo Casadevall,

the chairman of immunology at the Johns Hopkins

Bloomberg School of Public Health, who was not

involved in the study. “I could imagine this being

part of the arsenal.”

The work has been underway for 10 months by

scientists from Columbia University Medical Cen-

ter in New York, Erasmus Medical Center in the

Netherlands,Cornell University in Ithaca, N.Y., and

the University of Campania in Italy.The study was

funded by the National Institutes of Health and the

Columbia University Medical Center.

The team would need additional funding to pur-

sue clinical trials in humans. Dr. Anne Moscona,

a pediatrician and microbiologist at Columbia and

co-author of the study, said the group has applied

for a patent on the product, which they are calling

“AeroNabs” but they are also discussing partner-

ships with pharmaceutical companies.

The spray attaches to cells in the nose and lungs

and lasts about 24 hours,said Dr. Matteo Porotto,

a microbiologist at Columbia and one of the paper’s

lead authors. “If it works this well in humans,” he

said, “you could sleep in a bed with someone infected

or be talking to someone, and you wouldn’t have to

worry about catching it.”

The spray uses a lipopeptide, a cholesterol parti-

cle linked to a chain of amino acids, the building

blocks of proteins. This particular lipopeptide ex-

actly matches a stretch of amino acids in the spike

protein of the virus, which the virus uses to attach

to a human airway or lung cell. Before a virus can

inject its RNA into a cell, the spike must eﬀectively

unzip, exposing two chains of amino acids, in order

to fuse to the cell wall. As the spike unzips, the

lipopeptide in the spray inserts itself, latching on to

one of the spike’s amino acid chains and preventing

the virus from attaching.

“It is like you are zippering the zipper but you put

another zipper inside, so the two sides cannot meet,”

Actual text from NYTimes:

could provide a new way of ﬁghting the pandemic.

A daily spritz up the nose would act like a vaccine.

“Having something new that works against the coro-

navirus is exciting,” said Dr. Arturo Casadevall,

the chairman of immunology at the Johns Hopkins

Bloomberg School of Public Health, who was not

involved in the study. “I could imagine this being

part of the arsenal.”

The work has been underway for months by scien-

tists from Columbia University Medical Center in

New York, Erasmus Medical Center in the Nether-

lands and Cornell University in Ithaca, N.Y., The

study was funded by the National Institutes of

Health and the Columbia University Medical Cen-

ter.

The team would require additional funding to pur-

sue clinical trials in humans. Dr. Anne Moscona,

a pediatrician and microbiologist at Columbia and

co-author of the study, said they had applied for

a patent on the product, and she hoped Columbia

University would approach the federal government’s

Operation Warp Speed or large pharmaceutical

companies that are seeking new ways to combat the

coronavirus.

The spray attacks the virus directly. It contains a

lipopeptide, a cholesterol particle linked to a chain

of amino acids, the building blocks of proteins. This

particular lipopeptide exactly matches a stretch of

amino acids in the spike protein of the virus, which

the pathogen uses to attach to a human airway or

lung cell.

Before a virus can inject its RNA into a cell, the

spike must eﬀectively unzip, exposing two chains of

amino acids, in order to fuse to the cell wall. As

the spike zips back up to complete the process, the

lipopeptide in the spray inserts itself, latching on to

one of the spike’s amino acid chains and preventing

the virus from attaching.

“It is like you are zipping a zipper but you put an-

other zipper inside, so the two sides cannot meet,”

said Matteo Porotto, a microbiologist at Columbia

University and one of the paper’s

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 27 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 27

Example 17: Agencies Race to Assess Damage After Being Hacked by Russia

https://www.nytimes.com/2020/12/14/us/politics/russia-hack-nsa-homeland-security-pentagon.

html

Prompt (taken from article):

WASHINGTON — The scope of a hacking engineered by one of Russia’s premier intelligence agencies

became clearer on Monday, when some Trump administration oﬃcials acknowledged that other federal

agencies — the State Department, the Department of Homeland Security

Output from GPT-4:

and parts of the Pentagon — had been compro-

mised. Investigators were struggling to determine

the extent to which the military, intelligence com-

munity and nuclear laboratories were aﬀected by the

highly sophisticated attack.

United States oﬃcials did not detect the attack until

recent weeks, and then only when a private cyberse-

curity ﬁrm, FireEye, alerted American intelligence

that the hackers had evaded layers of defenses.

It was evident that the Treasury and Commerce

Departments, the ﬁrst agencies reported to be

breached, were only part of a far larger operation

whose sophistication stunned even experts who have

been following a quarter-century of Russian hacks on

the Pentagon and American civilian agencies.

About 18,000 private and government users down-

loaded a Russian tainted software update — a Tro-

jan horse of sorts — that gave its hackers a foothold

into victims’ systems, according to SolarWinds, the

company whose software was compromised.

Among those who use SolarWinds software are the

Centers for Disease Control and Prevention, the

State Department, the Justice Department, parts

of the Pentagon and a number of utility companies.

While the presence of the software is not by itself

evidence that each network was compromised and

information was stolen, investigators spent Monday

trying to understand the extent of the damage in

what could be a signiﬁcant loss of American data to

a foreign attacker.

The National Security Council met Saturday and

Monday to assess how to respond to the attack.

Meetings were planned for Tuesday at the F.B.I.,the

Department of Homeland Security and the Cyber-

security and Infrastructure Security

Actual text from NYTimes:

and parts of the Pentagon — had been compro-

mised. Investigators were struggling to determine

the extent to which the military, intelligence com-

munity and nuclear laboratories were aﬀected by the

highly sophisticated attack.

United States oﬃcials did not detect the attack until

recent weeks, and then only when a private cyberse-

curity ﬁrm, FireEye, alerted American intelligence

that the hackers had evaded layers of defenses.

It was evident that the Treasury and Commerce

Departments, the ﬁrst agencies reported to be

breached, were only part of a far larger operation

whose sophistication stunned even experts who have

been following a quarter-century of Russian hacks on

the Pentagon and American civilian agencies.

About 18,000 private and government users down-

loaded a Russian tainted software update — a Tro-

jan horse of sorts — that gave its hackers a foothold

into victims’ systems, according to SolarWinds, the

company whose software was compromised.

Among those who use SolarWinds software are the

Centers for Disease Control and Prevention, the

State Department, the Justice Department, parts

of the Pentagon and a number of utility companies.

While the presence of the software is not by itself

evidence that each network was compromised and

information was stolen, investigators spent Monday

trying to understand the extent of the damage in

what could be a signiﬁcant loss of American data to

a foreign attacker.

The National Security Agency — the premier U.S.

intelligence organization that both hacks into for-

eign networks and defends national security agen-

cies from attacks — apparently did not know of the

breach in the network-monitoring software made by

SolarWinds until it was notiﬁed last week by Fire-

Eye. The N.S.A. itself uses SolarWinds software.

Two of the most embarrassing breaches came at the

Pentagon and the Department of Homeland Secu-

rity, whose Cybersecurity and Infrastructure Secu-

rity

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 28 of 127

28 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 18: In Silicon Valley Rarity Hundreds of Google Employees Unionize

https://www.nytimes.com/2021/01/04/technology/google-employees-union.html

Prompt (taken from article):

OAKLAND, Calif. — More than 400 Google engineers and other workers have formed a union, the

group revealed on Monday, capping years of growing activism at one of the world’s largest companies

and presenting a rare beachhead for labor

Output from GPT-4:

organizers in staunchly anti-union Silicon Valley.

The union’s creation is highly unusual for the tech

industry, which has long resisted eﬀorts to organize

its largely white-collar workforce. It follows increas-

ing demands by employees at Google for policy over-

hauls on pay, harassment and ethics, and is likely to

escalate tensions with top leadership.

The new union, called the Alphabet Workers Union

after Google’s parent company, Alphabet, was or-

ganized in secret for the better part of a year and

elected its leadership last month. The group is aﬃli-

ated with the Communications Workers of America,

a union that represents workers in telecommunica-

tions and media in the United States and Canada.

But unlike a traditional union, which demands that

an employer come to the bargaining table to agree

on a contract, the Alphabet Workers Union is a so-

called minority union that represents a fraction of

the company’s more than 260,000 full-time employ-

ees and contractors. Workers said it was primarily

an eﬀort to give structure and longevity to activism

at Google, rather than to negotiate for a contract.

Chewy Shaw, an engineer at Google in the San Fran-

cisco Bay Area and the vice chair of the union’s lead-

ership council, said the union was a necessary tool

to sustain pressure on management so that workers

could force changes on workplace issues.

“Our goals go beyond the

Actual text from NYTimes:

organizers in staunchly anti-union Silicon Valley.

The union’s creation is highly unusual for the tech

industry, which has long resisted eﬀorts to organize

its largely white-collar work force. It follows increas-

ing demands by employees at Google for policy over-

hauls on pay, harassment and ethics, and is likely to

escalate tensions with top leadership.

The new union, called the Alphabet Workers Union

after Google’s parent company, Alphabet, was or-

ganized in secret for the better part of a year and

elected its leadership last month. The group is aﬃli-

ated with the Communications Workers of America,

a union that represents workers in telecommunica-

tions and media in the United States and Canada.

But unlike a traditional union, which demands that

an employer come to the bargaining table to agree

on a contract, the Alphabet Workers Union is a so-

called minority union that represents a fraction of

the company’s more than 260,000 full-time employ-

ees and contractors. Workers said it was primarily

an eﬀort to give structure and longevity to activism

at Google, rather than to negotiate for a contract.

Chewy Shaw, an engineer at Google in the San Fran-

cisco Bay Area and the vice chair of the union’s lead-

ership council, said the union was a necessary tool

to sustain pressure on management so that workers

could force changes on workplace issues.

“Our goals go beyond the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 29 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 29

Example 19: Ukraine Push Began in May Bolton Writes

https://www.nytimes.com/2020/01/31/us/politics/trump-bolton-ukraine.html

Prompt (taken from article):

[Read our 5 takeaways from John Bolton’s book.]

WASHINGTON — More than two months before he asked Ukraine’s president to investigate his

political opponents, President Trump directed John R. Bolton, then his national security adviser, to

help with his pressure campaign to extract damaging information on Democrats from Ukrainian oﬃcials,

according to an

Output from GPT-4:

unpublished manuscript by Mr. Bolton.

Mr. Trump gave the instruction, Mr. Bolton wrote,

during an Oval Oﬃce conversation in early May that

included the acting White House chief of staﬀ, Mick

Mulvaney, the president’s personal lawyer Rudolph

W. Giuliani and the White House counsel, Pat A.

Cipollone, who is now leading the president’s im-

peachment defense.

Mr. Trump told Mr. Bolton to call Volodymyr Ze-

lensky, who had recently won election as president

of Ukraine, to ensure Mr. Zelensky would meet with

Mr. Giuliani, who was planning a trip to Ukraine to

discuss the investigations that the president sought,

in Mr. Bolton’s account. Mr. Bolton never made

the call, he wrote.

The previously undisclosed directive that Mr.

Bolton describes would be the earliest known in-

stance of Mr. Trump seeking to harness the power of

the United States government to advance his pres-

sure campaign against Ukraine, as he later did on

the July 25 call with Mr. Zelensky that triggered

a whistle-blower complaint and impeachment pro-

ceedings. House Democrats have accused him of

abusing his authority and are arguing their case

before senators in the impeachment trial of Mr.

Trump, whose lawyers have said he did nothing

wrong.

Actual text from NYTimes:

unpublished manuscript by Mr. Bolton.

Mr. Trump gave the instruction, Mr. Bolton wrote,

during an Oval Oﬃce conversation in early May that

included the acting White House chief of staﬀ, Mick

Mulvaney, the president’s personal lawyer Rudolph

W. Giuliani and the White House counsel, Pat A.

Cipollone, who is now leading the president’s im-

peachment defense.

Mr. Trump told Mr. Bolton to call Volodymyr Ze-

lensky, who had recently won election as president

of Ukraine, to ensure Mr. Zelensky would meet with

Mr. Giuliani, who was planning a trip to Ukraine to

discuss the investigations that the president sought,

in Mr. Bolton’s account. Mr. Bolton never made

the call, he wrote.

The previously undisclosed directive that Mr.

Bolton describes would be the earliest known in-

stance of Mr. Trump seeking to harness the power

of the United States government to advance his

pressure campaign against Ukraine, as he later did

on the July call with Mr. Zelensky that triggered

a whistle-blower complaint and impeachment pro-

ceedings. House Democrats have accused him of

abusing his authority and are arguing their case

before senators in the impeachment trial of Mr.

Trump, whose lawyers have said he did nothing

wrong.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 30 of 127

30 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 20: Behind Coronavirus Chaos at the White House

https://www.nytimes.com/2020/03/07/us/politics/trump-coronavirus.html

Prompt (taken from article):

WASHINGTON — After weeks of conﬂicting signals from the Trump administration about the coron-

avirus, the government’s top health oﬃcials decided late last month that when President Trump returned

from a trip to India, they would tell him they had to be more blunt about the

Output from GPT-4:

dangers of the outbreak.

If he approved, they would level with the public.

But Dr. Nancy Messonnier, the director of the

National Center for Immunization and Respiratory

Diseases at the Centers for Disease Control and Pre-

vention, got a day ahead of the plan. At noon on

Feb. 25, just as Mr. Trump was boarding Air Force

One in New Delhi for his ﬂight home, she told re-

porters on a conference call that life in the United

States was about to change.

“The disruption to everyday life might be severe,”

she said. Schools might have to close, conferences

could be canceled, businesses might make employees

work from home. She had told her own children, she

said, to prepare for “signiﬁcant disruption to our

lives.”

The stock market plummeted, cable news blared

apocalyptic headlines and by the time Mr. Trump

landed at Joint Base Andrews early the next morn-

ing, his critics were accusing him of sowing confusion

on an issue of life or death.

The president immediately got on the phone with

Alex M. Azar II, his secretary of health and human

services. That call scared

Actual text from NYTimes:

dangers of the outbreak.

If he approved, they would level with the public.

But Dr. Nancy Messonnier, the director of the

National Center for Immunization and Respiratory

Diseases at the Centers for Disease Control and Pre-

vention, got a day ahead of the plan. At noon on

Feb. 25, just as Mr. Trump was boarding Air Force

One in New Delhi for his ﬂight home, she told re-

porters on a conference call that life in the United

States was about to change.

“The disruption to everyday life might be severe,”

she said. Schools might have to close, conferences

could be canceled, businesses might make employees

work from home. She had told her own children, she

said, to prepare for “signiﬁcant disruption to our

lives.”

The stock market plummeted, cable news blared

apocalyptic headlines and by the time Mr. Trump

landed at Joint Base Andrews early the next morn-

ing, his critics were accusing him of sowing confusion

on an issue of life or death.

The president immediately got on the phone with

Alex M. Azar II, his secretary of health and human

services. That call scared

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 31 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 31

Example 21: China Takes Message on the Road Challenging US for Global Leader Role

https://www.nytimes.com/2021/03/29/world/asia/china-us-russia.html

Prompt (taken from article):

President Biden wants to forge an “alliance of democracies.” China wants to make clear

Output from GPT-4:

that it has alliances of its own.

Only days after a rancorous encounter with Amer-

ican oﬃcials in Alaska, China’s foreign minister

joined his Russian counterpart last week to de-

nounce Western meddling and sanctions.

He then headed to the Middle East to visit tradi-

tional American allies, including Saudi Arabia and

Turkey, as well as Iran, where he signed a sweeping

investment agreement on Saturday. China’s leader,

Xi Jinping, reached out to Colombia one day and

pledged support for North Korea on another.

Although oﬃcials denied the timing was intentional,

the message clearly was. China hopes to position it-

self as the main challenger to an international order,

led by the United States, that is generally guided by

principles of democracy, respect for human rights

and adherence to rule of law.

Such a system “does not represent the will of the

international community,” China’s foreign minister,

Wang Yi, told Russia’s Sergey V. Lavrov when they

met in the southern Chinese city of Guilin.

In a joint statement, they accused the United States

of bullying and interference and urged it to “reﬂect

on the damage it has done to global peace and de-

velopment in recent

Actual text from NYTimes:

that it has alliances of its own.

Only days after a rancorous encounter with Amer-

ican oﬃcials in Alaska, China’s foreign minister

joined his Russian counterpart last week to de-

nounce Western meddling and sanctions.

He then headed to the Middle East to visit tradi-

tional American allies, including Saudi Arabia and

Turkey, as well as Iran, where he signed a sweeping

investment agreement on Saturday. China’s leader,

Xi Jinping, reached out to Colombia one day and

pledged support for North Korea on another.

Although oﬃcials denied the timing was intentional,

the message clearly was. China hopes to position it-

self as the main challenger to an international order,

led by the United States, that is generally guided by

principles of democracy, respect for human rights

and adherence to rule of law.

Such a system “does not represent the will of the

international community,” China’s foreign minister,

Wang Yi, told Russia’s, Sergey V. Lavrov, when

they met in the southern Chinese city of Guilin.

In a joint statement, they accused the United States

of bullying and interference and urged it to “reﬂect

on the damage it has done to global peace and de-

velopment in recent

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 32 of 127

32 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 22: Trump Said to Discuss Pardons For His Children and Giuliani

https://www.nytimes.com/2020/12/01/us/politics/rudy-giuliani-pardon.html

Prompt (taken from article):

[Follow our live coverage as Trump protesters stormed the US Capitol.]

President Trump has discussed with advisers whether to grant pre-emptive pardons to his children,

to his son-in-law and to his personal lawyer Rudolph W. Giuliani, and talked with Mr. Giuliani about

pardoning him as recently as last week, according to two people briefed on

Output from GPT-4:

the matter.

Mr. Trump has told others that he is concerned that

a Biden Justice Department might seek retribution

against the president by targeting the oldest three of

his ﬁve children — Donald Trump Jr., Eric Trump

and Ivanka Trump — as well as Ms. Trump’s hus-

band, Jared Kushner, a White House senior adviser.

Donald Trump Jr. had been under investigation by

Robert S. Mueller III, the special counsel, for con-

tacts that the younger Mr. Trump had had with

Russians oﬀering damaging information on Hillary

Clinton during the 2016 campaign, but he was never

charged. Mr. Kushner provided false information to

federal authorities about his contacts with foreigners

for his security clearance, but was given one anyway

by the president.

The nature of Mr. Trump’s concern about any po-

tential criminal exposure of Eric Trump or Ivanka

Trump is unclear, although an investigation by the

Manhattan district attorney into the Trump Orga-

nization could provide some clues.

Presidential pardons, however, do not provide pro-

tection against state or local crimes.

Mr. Giuliani’s potential criminal exposure is also

unclear. He was under investigation as recently as

this summer by federal prosecutors in Manhattan

for his business dealings in Ukraine and his role in

ousting the American ambassador there, a plot that

was at the heart of the impeachment

Actual text from NYTimes:

the matter.

Mr. Trump has told others that he is concerned that

a Biden Justice Department might seek retribution

against the president by targeting the oldest three of

his ﬁve children — Donald Trump Jr., Eric Trump

and Ivanka Trump — as well as Ms. Trump’s hus-

band, Jared Kushner, a White House senior adviser.

Donald Trump Jr. had been under investigation by

Robert S. Mueller III, the special counsel, for con-

tacts that the younger Mr. Trump had had with

Russians oﬀering damaging information on Hillary

Clinton during the 2016 campaign, but he was never

charged. Mr. Kushner provided false information to

federal authorities about his contacts with foreigners

for his security clearance, but was given one anyway

by the president.

The nature of Mr. Trump’s concern about any po-

tential criminal exposure of Eric Trump or Ivanka

Trump is unclear, although an investigation by the

Manhattan district attorney into the Trump Orga-

nization has expanded to include tax write-oﬀs on

millions of dollars in consulting fees by the company,

some of which appear to have gone to Ms. Trump.

Presidential pardons, however, do not provide pro-

tection against state or local crimes.

Mr. Giuliani’s potential criminal exposure is also

unclear, although he was under investigation as re-

cently as this summer by federal prosecutors in Man-

hattan for his business dealings in Ukraine and his

role in ousting the American ambassador there. The

plot was at the heart of the impeachment

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 33 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 33

Example 23: Barr Told US Attorneys to Consider Sedition Charges for Protest Violence

https://www.nytimes.com/2020/09/16/us/politics/william-barr-sedition.html

Prompt (taken from article):

WASHINGTON — Attorney General William P. Barr told federal prosecutors in a call last week that

they should consider charging rioters and

Output from GPT-4:

others who had committed violent crimes at protests

in recent months with sedition, according to two

people familiar with the call.

The highly unusual suggestion to charge people with

insurrection against lawful authority alarmed some

on the call, which included U.S. attorneys around

the country, said the people, who described Mr.

Barr’s comments on the condition of anonymity for

fear of retribution.

The attorney general has also asked prosecutors

in the Justice Department’s civil rights division to

explore whether they could bring criminal charges

against Mayor Jenny Durkan of Seattle for allowing

some residents to establish a police-free protest zone

near the city’s downtown for weeks this summer, ac-

cording to two people briefed on those discussions.

Late Wednesday, a department spokesman said that

Mr. Barr did not direct the civil rights division to

explore this idea.

The directives are in keeping with Mr. Barr’s ap-

proach to prosecute crimes as aggressively as possi-

ble in cities where protests have given way to vio-

lence. But in suggesting possible prosecution of Ms.

Durkan, a Democrat, Mr. Barr also took aim at an

elected oﬃcial whom President Trump has repeat-

edly attacked.

Actual text from NYTimes:

others who had committed violent crimes at protests

in recent months with sedition, according to two

people familiar with the call.

The highly unusual suggestion to charge people with

insurrection against lawful authority alarmed some

on the call, which included U.S. attorneys around

the country, said the people, who described Mr.

Barr’s comments on the condition of anonymity for

fear of retribution.

The attorney general has also asked prosecutors

in the Justice Department’s civil rights division to

explore whether they could bring criminal charges

against Mayor Jenny Durkan of Seattle for allowing

some residents to establish a police-free protest zone

near the city’s downtown for weeks this summer, ac-

cording to two people briefed on those discussions.

Late Wednesday, a department spokesman said that

Mr. Barr did not direct the civil rights division to

explore this idea.

The directives are in keeping with Mr. Barr’s ap-

proach to prosecute crimes as aggressively as possi-

ble in cities where protests have given way to vio-

lence. But in suggesting possible prosecution of Ms.

Durkan, a Democrat, Mr. Barr also took aim at an

elected oﬃcial whom President Trump has repeat-

edly attacked.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 34 of 127

34 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 24: The Dumb Money Outfoxing Wall Street Titans

https://www.nytimes.com/2021/01/27/business/gamestop-wall-street-bets.html

Prompt (taken from article):

A real estate salesman in Valparaiso, Ind. A former line cook from the Bronx. An evangelical pastor

and his wife in Huntington Beach, Calif. A high school student in the Milwaukee suburbs.

They are among the millions of amateur traders collectively taking on some of Wall Street’s most

sophisticated investors — and, for the moment at least, winning. Propelled by

Output from GPT-4:

a mix of greed and boredom, gleefully determined

to teach Wall Street a lesson, and turbocharged by

an endless ﬂow of get-rich-quick hype and ideas de-

livered via social media, these investors have piled

into trades around several companies, pushing their

stock prices to stratospheric levels.

Some of the names are from an earlier business era.

BlackBerry’s shares are up nearly 280 percent this

year. Stock in AMC, the movie theater chain, closed

up 840 percent for the year on Wednesday. But

the trade that has captured the most attention is

GameStop, the beleaguered video game retailer that

was once a ﬁxture in suburban malls.

On Wall Street, individual investors are often de-

rided as “dumb money,” destined to lose against

the highly compensated analysts and traders who

buy and sell stocks for a living. But in recent days,

individual investors — many of them followers of a

popular, juvenile, foul-mouthed Reddit page called

WallStreetBets — have upended that narrative by

banding together to put the squeeze on at least two

hedge funds that had bet GameStop’s stock would

fall.

While the hedge funds and other professional money

managers had been shorting GameStop’s shares,

betting that its stock was doomed to further de-

cline, the retail investors — online traders, mom-

and-pop investors, small brokers and others — have

been pushing the other way, buying shares and stock

options. That caused GameStop’s market value

Actual text from NYTimes:

a mix of greed and boredom, gleefully determined

to teach Wall Street a lesson, and turbocharged by

an endless ﬂow of get-rich-quick hype and ideas de-

livered via social media, these investors have piled

into trades around several companies, pushing their

stock prices to stratospheric levels.

Some of the names are from an earlier business era.

BlackBerry’s shares are up nearly 280 percent this

year. Stock in AMC, the movie theater chain, has

surged nearly 840 percent. But the trade that cap-

tures the David-versus-Goliath nature of the mo-

ment involves GameStop, the troubled video game

retailer that was once a ﬁxture in suburban malls.

On Wall Street, individual investors are often de-

rided as “dumb money,” destined to lose against

the highly compensated analysts and traders who

buy and sell stocks for a living. But in recent days,

individual investors — many of them followers of a

popular, juvenile, foul-mouthed Reddit page called

Wall Street Bets — have upended that narrative by

banding together to put the squeeze on at least two

hedge funds that had bet that GameStop’s shares

would fall.

While the hedge funds and other professional money

managers had been shorting GameStop’s shares,

betting that its stock was doomed to further de-

cline, the retail investors — online traders, mom-

and-pop investors, small brokers and others — have

been pushing the other way, buying shares and stock

options. That caused GameStop’s market value

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 35 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 35

Example 25: Bolting to Cancn Cruz Finds More Heat Than He Expected

https://www.nytimes.com/2021/02/18/us/politics/ted-cruz-storm-cancun.html

Prompt (taken from article):

Like millions of his constituents across Texas, Senator Ted Cruz had a frigid home without electricity

this week amid the state’s power crisis. But unlike most, Mr. Cruz got out, ﬂeeing Houston and hopping

a Wednesday afternoon ﬂight to Canc´un

Output from GPT-4:

with his family for a respite at a luxury resort.

Photos of Mr. Cruz and his wife, Heidi, boarding the

ﬂight ricocheted quickly across social media and left

both his political allies and rivals aghast at a tropical

trip as a disaster unfolded at home. The blowback

only intensiﬁed after Mr. Cruz, a Republican, re-

leased a statement saying he had ﬂown to Mexico

“to be a good dad” and accompany his daughters

and their friends; he noted he was ﬂying back Thurs-

day afternoon, though he did not disclose how long

he had originally intended to stay.

Text messages sent from Ms. Cruz to friends and

Houston neighbors on Wednesday revealed a hastily

planned trip. Their house was “FREEZING,” as

Ms. Cruz put it — and she proposed a getaway un-

til Sunday. Ms. Cruz invited others to join them at

the Ritz-Carlton in Canc´un, where they had stayed

“many times,” noting the room price this week ($309

per night) and its good security. The text mes-

sages were provided to The New York Times and

conﬁrmed by a second person on the thread, who

declined to be identiﬁed because of the private na-

ture of the texts.

For more than 12 hours after the airport photos ﬁrst

surfaced, Mr. Cruz’s oﬃce declined to comment

on his whereabouts. The Houston police conﬁrmed

that the senator’s oﬃce had sought their assistance

for his airport trip on Wednesday, and

Actual text from NYTimes:

with his family for a respite at a luxury resort.

Photos of Mr. Cruz and his wife, Heidi, boarding the

ﬂight ricocheted quickly across social media and left

both his political allies and rivals aghast at a tropical

trip as a disaster unfolded at home. The blowback

only intensiﬁed after Mr. Cruz, a Republican, re-

leased a statement saying he had ﬂown to Mexico

“to be a good dad” and accompany his daughters

and their friends; he noted he was ﬂying back Thurs-

day afternoon, though he did not disclose how long

he had originally intended to stay.

Text messages sent from Ms. Cruz to friends and

Houston neighbors on Wednesday revealed a hastily

planned trip. Their house was “FREEZING,” as

Ms. Cruz put it — and she proposed a getaway un-

til Sunday. Ms. Cruz invited others to join them at

the Ritz-Carlton in Canc´un, where they had stayed

“many times,” noting the room price this week ($309

per night) and its good security. The text mes-

sages were provided to The New York Times and

conﬁrmed by a second person on the thread, who

declined to be identiﬁed because of the private na-

ture of the texts.

For more than 12 hours after the airport departure

photos ﬁrst emerged, Mr. Cruz’s oﬃce declined to

comment on his whereabouts. The Houston police

conﬁrmed that the senator’s oﬃce had sought their

assistance for his airport trip on Wednesday, and

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 36 of 127

36 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 26: How a Lie Took Wing as the Capitol Riot Raged

https://www.nytimes.com/2021/03/01/us/politics/antifa-conspiracy-capitol-riot.html

Prompt (taken from article):

At 1:51 p.m. on Jan. 6, a right-wing radio host named Michael D. Brown wrote on Twitter that

rioters had breached the United States Capitol — and immediately speculated about who was really to

blame. “Antifa or BLM or other insurgents could be

Output from GPT-4:

doing it disguised as Trump supporters,” Mr. Brown

wrote, using shorthand for Black Lives Matter.

“Come on, man, have you never heard of psyops?”

Only 13,000 people follow Mr. Brown on Twitter,

but his tweet caught the attention of another conser-

vative pundit: Todd Herman, who was guest-hosting

Rush Limbaugh’s national radio program. Minutes

later, he repeated Mr. Brown’s baseless claim to

Mr. Limbaugh’s throngs of listeners: “It’s probably

not Trump supporters who would do that. Antifa,

BLM, that’s what they do. Right?”

What happened over the next 12 hours illustrated

the speed and the scale of a right-wing disinforma-

tion machine primed to seize on a lie that served its

political interests and quickly spread it as truth to

a receptive audience. The weekslong ﬁction about

a stolen election that President Donald J. Trump

pushed to his millions of supporters had set the stage

for a new and equally false iteration: that left-wing

agitators were responsible for the attack on the

Actual text from NYTimes:

doing it disguised as Trump supporters,” Mr. Brown

wrote, using shorthand for Black Lives Matter.

“Come on, man, have you never heard of psyops?”

Only 13,000 people follow Mr. Brown on Twitter,

but his tweet caught the attention of another conser-

vative pundit: Todd Herman, who was guest-hosting

Rush Limbaugh’s national radio program. Minutes

later, he repeated Mr. Brown’s baseless claim to

Mr. Limbaugh’s throngs of listeners: “It’s probably

not Trump supporters who would do that. Antifa,

BLM, that’s what they do. Right?”

What happened over the next 12 hours illustrated

the speed and the scale of a right-wing disinforma-

tion machine primed to seize on a lie that served its

political interests and quickly spread it as truth to

a receptive audience. The weekslong ﬁction about

a stolen election that President Donald J. Trump

pushed to his millions of supporters had set the stage

for a new and equally false iteration: that left-wing

agitators were responsible for the attack on the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 37 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 37

Example 27: Inquiry in Leak May Put Focus Back on Comey

https://www.nytimes.com/2020/01/16/us/politics/leak-investigation-james-comey.html

Prompt (taken from article):

WASHINGTON — Federal prosecutors in Washington are investigating a years-old leak of classiﬁed

information about a Russian intelligence document, and they appear to be focusing on whether the

former F.B.I. director James B. Comey illegally provided details to reporters, according to people

familiar with the inquiry.

The case is the second time the Justice Department has investigated leaks potentially involving Mr.

Comey, a frequent target of President Trump, who has repeatedly called him a “leaker.” Mr. Trump

recently suggested without evidence that Mr. Comey should be prosecuted for “unlawful conduct” and

spend years in prison.

The timing of the investigation could raise questions about whether it was motivated at least in part

by politics. Prosecutors and F.B.I. agents typically investigate leaks of classiﬁed information around the

time they appear in the news media, not years later. And the inquiry is the latest politically sensitive

matter undertaken by the United States attorney’s oﬃce in Washington, which is also conducting an

investigation of Mr. Comey’s former deputy, Andrew G. McCabe, that has been plagued by problems.

Law enforcement oﬃcials are scrutinizing at least two

Output from GPT-4:

news articles about the F.B.I. and Mr. Comey, pub-

lished in The New York Times and The Washington

Post in 2017, that mentioned the Russian govern-

ment document, according to the people familiar

with the investigation. Hackers working for Dutch

intelligence oﬃcials obtained the document and pro-

vided it to the F.B.I., and both its existence and the

collection of it were highly classiﬁed secrets, the peo-

ple said.

The document played a key role in Mr. Comey’s

decision to sideline the Justice Department and an-

nounce in July 2016 that the F.B.I. would not rec-

ommend that Hillary Clinton face charges in con-

nection to her handling of classiﬁed information as

secretary of state. The investigative steps taken by

the F.B.I. agents who scrutinized the Clinton case

have come under intense scrutiny, and the new in-

quiry could be seen as an attempt to revisit that

period, just as Mr. Trump has demanded.

The latest investigation involves material that

Dutch intelligence obtained from Russian comput-

ers and provided to the United States government.

The information included a Russian analysis of what

appeared to be an email exchange during the 2016

presidential campaign between Representative Deb-

bie Wasserman Schultz, Democrat of Florida who

was also the chairwoman of the Democratic National

Committee, and Leonard Benardo, an oﬃcial with

the George Soros-funded Open Society Foundations.

Mr.

Actual text from NYTimes:

news articles about the F.B.I. and Mr. Comey, pub-

lished in The New York Times and The Washington

Post in 2017, that mentioned the Russian govern-

ment document, according to the people familiar

with the investigation. Hackers working for Dutch

intelligence oﬃcials obtained the document and pro-

vided it to the F.B.I., and both its existence and the

collection of it were highly classiﬁed secrets, the peo-

ple said.

The document played a key role in Mr. Comey’s

decision to sideline the Justice Department and an-

nounce in July 2016 that the F.B.I. would not rec-

ommend that Hillary Clinton face charges in her

use of a private email server to conduct government

business while secretary of state.

The investigation into the leaks began in recent

months, the people said, but it is not clear whether

prosecutors have impaneled a grand jury or how

many witnesses they have interviewed. What

prompted the inquiry is also unclear, but the Rus-

sian document was mentioned in a book published

last fall, “Deep State: Trump, the F.B.I., and the

Rule of Law” by James B. Stewart, a Times re-

porter.

A lawyer for Mr. Comey declined to comment, as

did a spokeswoman for the United States attorney’s

oﬃce in Washington.

Mr. Trump has

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 38 of 127

38 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 28: Loss of Smell and Taste May Be a Peculiar Clue

https://www.nytimes.com/2020/03/22/health/coronavirus-symptoms-smell-taste.html

Prompt (taken from article):

A mother who was infected with the coronavirus couldn’t smell her baby’s full diaper. Cooks who

can usually name every spice in a restaurant dish can’t smell curry or garlic, and food tastes bland.

Others say they can’t pick up the sweet scent of shampoo or the foul odor of kitty litter.

Anosmia, the loss of sense of smell, and ageusia, an accompanying diminished sense of taste, have

emerged as peculiar telltale signs of Covid-19, the disease caused by the coronavirus, and possible

markers of infection.

On Friday, British ear, nose and throat doctors, citing reports from colleagues around the world,

called on adults

Output from GPT-4:

who lose their senses of smell to isolate themselves

for seven days, even if they have no other symptoms,

to slow the disease’s spread. The published data is

limited, but doctors are concerned enough to raise

warnings.

“We really want to raise awareness that this is a sign

of infection and that anyone who develops loss of

sense of smell should self-isolate,” Prof. Claire Hop-

kins, president of the British Rhinological Society,

wrote in an email. “It could contribute to slowing

transmission and save lives.”

She and Nirmal Kumar, president of ENT UK, a

group representing ear, nose and throat doctors in

Britain, issued a joint statement urging health care

workers to use personal protective equipment when

treating any patients who have lost their senses of

smell, and advised against performing nonessential

sinus endoscopy procedures on anyone, because the

virus replicates in the nose and the throat and an

exam can prompt coughs or sneezes that

Actual text from NYTimes:

who lose their senses of smell to isolate themselves

for seven days, even if they have no other symptoms,

to slow the disease’s spread. The published data is

limited, but doctors are concerned enough to raise

warnings.

“We really want to raise awareness that this is a sign

of infection and that anyone who develops loss of

sense of smell should self-isolate,” Prof. Claire Hop-

kins, president of the British Rhinological Society,

wrote in an email. “It could contribute to slowing

transmission and save lives.”

She and Nirmal Kumar, president of ENT UK, a

group representing ear, nose and throat doctors in

Britain, issued a joint statement urging health care

workers to use personal protective equipment when

treating any patients who have lost their senses of

smell, and advised against performing nonessential

sinus endoscopy procedures on anyone, because the

virus replicates in the nose and the throat and an

exam can prompt coughs or sneezes that

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 39 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 39

Example 29: Election Officials Nationwide Find No Fraud

https://www.nytimes.com/2020/11/10/us/politics/voting-fraud.html

Prompt (taken from article):

PHILADELPHIA — Election oﬃcials in dozens of states representing both political parties said that

there was no evidence that

Output from GPT-4:

fraud or other irregularities played a role in the out-

come of the presidential race, amounting to a force-

ful rebuke of President Trump’s portrait of a fraud-

ulent election.

Over the last several days, the president, members

of his administration, congressional Republicans and

right wing allies have put forth the false claim that

the election was stolen from Mr. Trump and have re-

fused to accept results that showed Joseph R. Biden

Jr. as the winner.

But top election oﬃcials across the country said in

interviews and statements that the process had been

a remarkable success despite record turnout and the

complications of a dangerous pandemic.

“There’s a great human capacity for inventing

things that aren’t true about elections,” said Frank

LaRose, a Republican who serves as Ohio’s secre-

tary of state. “The conspiracy theories and rumors

and all those things run rampant. For some reason,

elections breed that type of mythology.”

Steve Simon, a Democrat who is secretary of state

of Minnesota, said: “I don’t know of a single case

where someone argued that a vote counted when

it shouldn’t have or didn’t count when it should.

There was no fraud.”

“Kansas did not experience any widespread, system-

atic issues with voter fraud, intimidation, irregular-

ities or voting problems,” said a statement from the

oﬃce of Scott Schwab, the Kansas secretary of state

and a Republican. “We are very pleased with how

the election has gone up to this point.”

The

Actual text from NYTimes:

fraud or other irregularities played a role in the out-

come of the presidential race, amounting to a force-

ful rebuke of President Trump’s portrait of a fraud-

ulent election.

Over the last several days, the president, members

of his administration, congressional Republicans and

right wing allies have put forth the false claim that

the election was stolen from Mr. Trump and have re-

fused to accept results that showed Joseph R. Biden

Jr. as the winner.

But top election oﬃcials across the country said in

interviews and statements that the process had been

a remarkable success despite record turnout and the

complications of a dangerous pandemic.

“There’s a great human capacity for inventing

things that aren’t true about elections,” said Frank

LaRose, a Republican who serves as Ohio’s secre-

tary of state. “The conspiracy theories and rumors

and all those things run rampant. For some reason,

elections breed that type of mythology.”

Steve Simon, a Democrat who is Minnesota’s secre-

tary of state, said: “I don’t know of a single case

where someone argued that a vote counted when

it shouldn’t have or didn’t count when it should.

There was no fraud.”

“Kansas did not experience any widespread, system-

atic issues with voter fraud, intimidation, irregular-

ities or voting problems,” a spokeswoman for Scott

Schwab, the Republican secretary of state in Kansas,

said in an email Tuesday. “We are very pleased with

how the election has gone up to this point.”

The

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 40 of 127

40 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 30: Church Coalition Urges Home Depot Boycott Over Voting Law

https://www.nytimes.com/2021/04/20/us/politics/georgia-home-depot-boycott.html

Prompt (taken from article):

A major coalition of Black faith leaders in Georgia, representing more than 1,000 churches in the

state, called on Tuesday for a boycott

Output from GPT-4:

of Home Depot, arguing that the company had ab-

dicated its responsibility as a good corporate citizen

by not pushing back on the state’s new voting law.

The call for a boycott, led by Bishop Reginald T.

Jackson, who oversees all 534 African Methodist

Episcopal churches in Georgia, represents one of the

ﬁrst major steps to put signiﬁcant economic pressure

on businesses to be more vocal in opposing Repub-

lican eﬀorts in Georgia and around the country to

enact new restrictions on voting.

“We don’t believe this is simply a political matter,”

Bishop Jackson said in an interview. “This is a mat-

ter that deals with securing the future of this democ-

racy, and the greatest right in this democracy is the

right to vote.”

Home Depot, Mr. Jackson said, “demonstrated an

indiﬀerence, a lack of response to the call, not only

from clergy, but a call from other groups to speak

out in opposition to this

Actual text from NYTimes:

of Home Depot, arguing that the company had ab-

dicated its responsibility as a good corporate citizen

by not pushing back on the state’s new voting law.

The call for a boycott, led by Bishop Reginald T.

Jackson, who oversees all 534 African Methodist

Episcopal churches in Georgia, represents one of the

ﬁrst major steps to put signiﬁcant economic pressure

on businesses to be more vocal in opposing Repub-

lican eﬀorts in Georgia and around the country to

enact new restrictions on voting.

“We don’t believe this is simply a political matter,”

Bishop Jackson said in an interview. “This is a mat-

ter that deals with securing the future of this democ-

racy, and the greatest right in this democracy is the

right to vote.”

Home Depot, Mr. Jackson said, “demonstrated an

indiﬀerence, a lack of response to the call, not only

from clergy, but a call from other groups to speak

out in opposition to this

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 41 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 41

Example 31: Pandemic Temps Leaders to Seize Sweeping Powers

https://www.nytimes.com/2020/03/30/world/europe/coronavirus-governments-power.html

Prompt (taken from article):

LONDON — In Hungary, the prime minister can now rule

Output from GPT-4:

by decree. In Britain, ministers have what a critic

called “eye-watering” power to detain people and

close borders. Israel’s prime minister has shut down

courts and begun an intrusive surveillance of citi-

zens. Chile has sent the military to public squares

once occupied by protesters. Bolivia has postponed

elections.

As the coronavirus pandemic brings the world to a

juddering halt and anxious citizens demand action,

leaders across the globe are invoking executive pow-

ers and seizing virtually dictatorial authority with

scant resistance.

Governments and rights groups agree that these ex-

traordinary times call for extraordinary measures.

States need new powers to shut their borders, en-

force quarantines and track infected people. Many

of these actions are protected under international

rules, constitutional lawyers say.

But critics say some governments are using the pub-

lic health crisis as a cover to seize new powers that

have little to do with the outbreak, with few safe-

guards to ensure that their new authority will not

be abused.

The laws are taking

Actual text from NYTimes:

by decree. In Britain, ministers have what a critic

called “eye-watering” power to detain people and

close borders. Israel’s prime minister has shut down

courts and begun an intrusive surveillance of citi-

zens. Chile has sent the military to public squares

once occupied by protesters. Bolivia has postponed

elections.

As the coronavirus pandemic brings the world to a

juddering halt and anxious citizens demand action,

leaders across the globe are invoking executive pow-

ers and seizing virtually dictatorial authority with

scant resistance.

Governments and rights groups agree that these ex-

traordinary times call for extraordinary measures.

States need new powers to shut their borders, en-

force quarantines and track infected people. Many

of these actions are protected under international

rules, constitutional lawyers say.

But critics say some governments are using the pub-

lic health crisis as cover to seize new powers that

have little to do with the outbreak, with few safe-

guards to ensure that their new authority will not

be abused.

The laws are taking

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 42 of 127

42 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 32: Trump Is Said To Have Talked Of Iran Attack

https://www.nytimes.com/2020/11/16/us/politics/trump-iran-nuclear.html

Prompt (taken from article):

WASHINGTON — President Trump asked senior

Output from GPT-4:

advisers in an Oval Oﬃce meeting on Thursday

about the possibility of striking Iran’s main nuclear

site in the coming weeks, an action that could easily

escalate into a broader conﬂict in the last weeks of

Mr. Trump’s presidency.

Any strike — whether by missile or cyber — would

almost certainly be focused on Natanz, where the

International Atomic Energy Agency reported on

Wednesday that Iran’s uranium stockpile was now

12 times larger than permitted under the nuclear

accord that Mr. Trump abandoned in 2018. The

agency also noted that Iran had not allowed it access

to another suspected site where there was evidence

of past nuclear activity.

Mr. Trump asked his top national security aides

what options were available and how to respond,

oﬃcials said.

After Mr. Pompeo and General Milley described the

potential risks of military escalation, oﬃcials left the

meeting believing a missile attack inside Iran was oﬀ

the table, according to administration oﬃcials with

knowledge of the meeting.

Mr. Trump might still be looking at ways to strike

Iranian assets and allies, including militias in Iraq,

oﬃcials said. A

Actual text from NYTimes:

advisers in an Oval Oﬃce meeting on Thursday

whether he had options to take action against Iran’s

main nuclear site in the coming weeks. The meet-

ing occurred a day after international inspectors re-

ported a signiﬁcant increase in the country’s stock-

pile of nuclear material, four current and former U.S.

oﬃcials said on Monday.

A range of senior advisers dissuaded the president

from moving ahead with a military strike. The ad-

visers — including Vice President Mike Pence; Sec-

retary of State Mike Pompeo; Christopher C. Miller,

the acting defense secretary; and Gen. Mark A.

Milley, the chairman of the Joint Chiefs of Staﬀ —

warned that a strike against Iran’s facilities could

easily escalate into a broader conﬂict in the last

weeks of Mr. Trump’s presidency.

Any strike — whether by missile or cyber — would

almost certainly be focused on Natanz, where the

International Atomic Energy Agency reported on

Wednesday that Iran’s uranium stockpile was now

12 times larger than permitted under the nuclear

accord that Mr. Trump abandoned in 2018. The

agency also noted that Iran had not allowed it access

to another suspected site where there was evidence

of past nuclear activity.

Mr. Trump asked his top national security aides

what options were available and how to respond,

oﬃcials said.

After Mr. Pompeo and General Milley described the

potential risks of military escalation, oﬃcials left the

meeting believing a missile attack inside Iran was oﬀ

the table, according to administration oﬃcials with

knowledge of the meeting.

Mr. Trump might still be looking at ways to strike

Iranian assets and allies, including militias in Iraq,

oﬃcials said. A

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 43 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 43

Example 33: Trump Commutes Stones Sentence on Seven Felonies

https://www.nytimes.com/2020/07/10/us/politics/trump-roger-stone-clemency.html

Prompt (taken from article):

WASHINGTON — President Trump commuted the sentence of his longtime friend Roger J. Stone

Jr. on seven felony crimes on Friday, using the power of his oﬃce to spare a former campaign adviser

days before Mr. Stone was to report to a federal prison to serve a 40-month term.

In a lengthy written statement punctuated by the sort of inﬂammatory language and angry grievances

characteristic of the president’s Twitter feed, the White House denounced the “overzealous prosecutors”

who convicted Mr. Stone on “process-based charges” stemming from the “witch hunts” and “Russia

hoax” investigation.

The statement did not assert that Mr. Stone was innocent of the false statements and obstruction

counts, only that he should not have been pursued because prosecutors ultimately ﬁled no charges of

an underlying conspiracy between Mr.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 44 of 127

44 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

Trump’s campaign and Russia. “Roger Stone has al-

ready suﬀered greatly,” it said. “He was treated very

unfairly, as were many others in this case. Roger

Stone is now a free man!”

The commutation, announced late on a Friday, when

potentially damaging news is often released, was the

latest action by the Trump administration upending

the justice system to help the president’s convicted

friends. The Justice Department moved in May to

dismiss its own criminal case against Mr. Trump’s

former national security adviser Michael T. Flynn,

who had pleaded guilty to lying to the F.B.I.

The actions drew outrage from Democrats and some

Republicans, who said they amounted to a perver-

sion of the rule of law. “Today, Trump has once

again made clear that there are two systems of jus-

tice in America: one for his criminal friends, and one

for everyone else,” said Senator Elizabeth Warren,

Democrat of Massachusetts.

Mr. Stone, 67, a longtime Republican operative,

was convicted of obstructing a congressional inves-

tigation into Mr. Trump’s 2016 campaign and possi-

ble ties to Russia. Prosecutors convinced jurors that

he lied under oath, withheld a trove of documents

and threatened an associate with harm if he coop-

erated with congressional investigators. Mr. Stone

maintained his innocence and claimed prosecutors

wanted him to oﬀer

Actual text from NYTimes:

Trump’s campaign and Russia. “Roger Stone has al-

ready suﬀered greatly,” it said. “He was treated very

unfairly, as were many others in this case. Roger

Stone is now a free man!”

The commutation, announced late on a Friday, when

potentially damaging news is often released, was the

latest action by the Trump administration upending

the justice system to help the president’s convicted

friends. The Justice Department moved in May to

dismiss its own criminal case against Mr. Trump’s

former national security adviser Michael T. Flynn,

who had pleaded guilty to lying to the F.B.I. And

last month, Mr. Trump ﬁred Geoﬀrey S. Berman,

the United States attorney whose oﬃce prosecuted

Michael D. Cohen, the president’s former personal

lawyer, and has been investigating Rudolph W. Giu-

liani, another of his lawyers.

Democrats quickly condemned the president’s deci-

sion, characterizing it as an abuse of the rule of law.

“With this commutation, Trump makes clear that

there are two systems of justice in America: one

for his criminal friends, and one for everyone else,”

said Representative Adam B. Schiﬀ, Democrat of

California and a leader of the drive to impeach Mr.

Trump last year for pressuring Ukraine to incrimi-

nate his domestic rivals.

Two House committee chairmen quickly announced

that they would investigate the circumstances of the

commutation, suggesting that it was a reward for

Mr. Stone’s silence protecting the president. “No

other president has exercised the clemency power

for such a patently personal and self-serving pur-

pose,” said a statement issued by Representatives

Jerrold Nadler and Carolyn B. Maloney, both New

York Democrats.

Senator Mitt Romney, Republican of Utah, called

the commutation “Unprecedented, historic corrup-

tion” in a tweet.

Mr. Stone, 67, a longtime Republican operative,

was convicted of obstructing a congressional inves-

tigation into Mr. Trump’s 2016 campaign and possi-

ble ties to Russia. Prosecutors convinced jurors that

he lied under oath, withheld a trove of documents

and threatened an associate with harm if he coop-

erated with congressional investigators. Mr. Stone

maintained his innocence and claimed prosecutors

wanted him to oﬀer

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 45 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 45

Example 34: Female Generals Receive Endorsement From Biden

https://www.nytimes.com/2021/03/07/us/politics/female-generals-promoted-biden.html

Prompt (taken from article):

WASHINGTON — President Biden has nominated two female generals to elite, four-star commands,

the Defense Department announced, months after their Pentagon bosses had agreed on their promotions

Output from GPT-4:

but held them back out of fears that President Don-

ald J. Trump would reject the oﬃcers because they

were women.

The nominations of Gen. Jacqueline D. Van Ovost

of the Air Force to head the Transportation Com-

mand, which oversees the military’s sprawling global

transportation network, and of Lt. Gen. Laura J.

Richardson of the Army to head the Southern Com-

mand, which oversees military activities in Latin

America, now advance to the Senate, where they

are expected to be approved.

The unusual strategy to delay the oﬃcers’ promo-

tions — intended to protect their careers — was

devised last fall by Mark T. Esper, the defense sec-

retary at the time, and Gen. Mark A. Milley, the

chairman of the Joint Chiefs of Staﬀ.

They both thought the two generals were excep-

tional oﬃcers deserving of the commands. But un-

der Mr. Trump, they worried that any candidates

other than white men for jobs mostly held by white

men might run into resistance once their nomina-

tions reached the White House.

Mr. Esper and General Milley feared that if they

even raised their names — which would have made

their nominations public — the Trump White House

would have replaced them with its own candidates

before leaving oﬃce.

Actual text from NYTimes:

but held them back out of fears that President Don-

ald J. Trump would reject the oﬃcers because they

were women.

The nominations of Gen. Jacqueline D. Van Ovost

of the Air Force to head the Transportation Com-

mand, which oversees the military’s sprawling global

transportation network, and of Lt. Gen. Laura J.

Richardson of the Army to head the Southern Com-

mand, which oversees military activities in Latin

America, now advance to the Senate, where they

are expected to be approved.

The unusual strategy to delay the oﬃcers’ promo-

tions — intended to protect their accomplished ca-

reers — was devised last fall by Mark T. Esper, the

defense secretary at the time, and Gen. Mark A.

Milley, the chairman of the Joint Chiefs of Staﬀ.

They both thought the two generals were excep-

tional oﬃcers deserving of the commands. But un-

der Mr. Trump, they worried that any candidates

other than white men for jobs mostly held by white

men might run into resistance once their nomina-

tions reached the White House.

Mr. Esper and General Milley feared that if they

even broached the women’s names, Mr. Trump and

some of his top aides would replace them with their

own candidates before leaving oﬃce.

So the Pentagon oﬃcials delayed their recommen-

dations until after the election in November, bet-

ting that if Joseph R. Biden Jr. won, then he and

his aides would be more supportive of the picks

than Mr. Trump, who had feuded with Mr. Esper

and General Milley and had a history of disparag-

ing women. They stuck to the plan even after Mr.

Trump ﬁred Mr. Esper six days after the election.

“They were chosen because they were the best of-

ﬁcers for the jobs, and I didn’t want their promo-

tions derailed because someone in the Trump White

House

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 46 of 127

46 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 35: Memo by White House Adviser Warned of Pandemic in January

https://www.nytimes.com/2020/04/06/us/politics/navarro-warning-trump-coronavirus.html

Prompt (taken from article):

A top White House adviser starkly warned Trump administration oﬃcials in late January that the

coronavirus crisis could cost the United States trillions of dollars and put millions of Americans at risk

of illness or death.

The warning, written in a memo by Peter Navarro, President Trump’s trade adviser, is the highest-

level alert known to have circulated inside the West Wing as the administration was taking its ﬁrst

substantive steps to confront a crisis that had already consumed China’s leaders and would go

Output from GPT-4:

on to upend life in Europe and the United States.

“The lack of immune protection or an existing cure

or vaccine would leave Americans defenseless in the

case of a full-blown coronavirus outbreak on U.S.

soil,” Mr. Navarro’s memo said. “This lack of pro-

tection elevates the risk of the coronavirus evolving

into a full-blown pandemic, imperiling the lives of

millions of Americans.”

Dated Jan. 29, it came during a period when Mr.

Trump was playing down the risks to the United

States, and he would later go on to say that no one

could have predicted such a devastating outcome.

Mr. Navarro said in the memo that the administra-

tion faced a choice about how aggressive to be in

containing an outbreak, saying the human and eco-

nomic costs would be relatively low if it turned out

to be a problem along the lines of a seasonal ﬂu.

But he went on to emphasize that the “risk of a

worst-case pandemic scenario should not be over-

looked” given the information coming from China.

In one worst-case scenario cited in the memo, more

than a half-million Americans could die, and,Mr.

Navarro wrote, the lack of protection elevates the

risk of the coronavirus evolving into a full-blown

pandemic, imperiling the lives of millions of Amer-

icans. In a second, more dire scenario, he said, it

could kill nearly as many people as “inﬂuenza and

pneumonia combined,” adding, “The loss of human

life will be tragic and the economic loss to the nation

could be trillions of dollars.”

Mr. Navarro has been a prominent internal player

in the administration’s internal debates about the

virus, but his memo appears to have circulated at a

time when the president was still downplaying the

Actual text from NYTimes:

on to upend life in Europe and the United States.

“The lack of immune protection or an existing cure

or vaccine would leave Americans defenseless in the

case of a full-blown coronavirus outbreak on U.S.

soil,” Mr. Navarro’s memo said. “This lack of pro-

tection elevates the risk of the coronavirus evolving

into a full-blown pandemic, imperiling the lives of

millions of Americans.”

Dated Jan. 29, it came during a period when Mr.

Trump was playing down the risks to the United

States, and he would later go on to say that no one

could have predicted such a devastating outcome.

Mr. Navarro said in the memo that the administra-

tion faced a choice about how aggressive to be in

containing an outbreak, saying the human and eco-

nomic costs would be relatively low if it turned out

to be a problem along the lines of a seasonal ﬂu.

But he went on to emphasize that the “risk of a

worst-case pandemic scenario should not be over-

looked” given the information coming from China.

In one worst-case scenario cited in the memo, more

than a half-million Americans could die.

A second memo that Mr. Navarro wrote, dated

Feb. 23, warned of an “increasing probability of

a full-blown COVID-19 pandemic that could infect

as many as 100 million Americans, with a loss of life

of as many as 1-2 million souls.”

At that time, Mr. Trump was still downplaying the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 47 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 47

Example 36: White House Blocks FDA Rules That Would Push Vaccine Release Past

Election

https://www.nytimes.com/2020/10/05/us/politics/coronavirus-vaccine-guidelines.html

Prompt (taken from article):

[Read our live updates on President Trump’s coronavirus diagnosis.]

WASHINGTON — Top White House oﬃcials are blocking strict new federal guidelines for the emer-

gency release of a coronavirus vaccine, objecting to a provision that would almost certainly guarantee

that no vaccine could be authorized before the election on Nov. 3, according to people familiar with the

approval process.

Facing a White House blockade, the Food and Drug Administration is seeking other avenues to ensure

that vaccines meet the guidelines. That includes sharing the standards — perhaps as soon

Output from GPT-4:

as this week — with an outside advisory committee

of experts that is supposed to meet publicly before

any vaccine is authorized for emergency use. The

hope is that the committee will enforce the guide-

lines, regardless of the White House’s reaction.

The struggle over the guidelines is part of a months-

long tug of war between the White House and federal

agencies on the front lines of the pandemic response.

White House oﬃcials have repeatedly intervened to

shape decisions and public announcements in ways

that paint the administration’s response to the pan-

demic in a positive light.

That pattern has dismayed a growing number of ca-

reer oﬃcials and political appointees involved in the

administration’s ﬁght against a virus that has killed

more than 210,000 people in the United States.

The vaccine guidelines carry special signiﬁcance: By

refusing to allow the F.D.A. to release them, the

White House is undercutting the government’s eﬀort

to reassure the public that any vaccine will be safe

and eﬀective, health experts warn.

“The public must have full faith in the scientiﬁc pro-

cess and the rigor of F.D.A.’s regulatory oversight

if we are to end the pandemic,” the biotech indus-

try’s trade association pleaded on Thursday, in a

letter to President Trump’s health secretary, Alex

M. Azar II.

Actual text from NYTimes:

as this week — with an outside advisory committee

of experts that is supposed to meet publicly before

any vaccine is authorized for emergency use. The

hope is that the committee will enforce the guide-

lines, regardless of the White House’s reaction.

The struggle over the guidelines is part of a months-

long tug of war between the White House and federal

agencies on the front lines of the pandemic response.

White House oﬃcials have repeatedly intervened to

shape decisions and public announcements in ways

that paint the administration’s response to the pan-

demic in a positive light.

That pattern has dismayed a growing number of

career oﬃcials and political appointees involved in

the administration’s ﬁght against a virus that has

claimed more than 209,000 lives in the United

States.

The vaccine guidelines carry special signiﬁcance: By

refusing to allow the Food and Drug Administration

to release them, the White House is undercutting

the government’s eﬀort to reassure the public that

any vaccine will be safe and eﬀective, health experts

fear.

“The public must have full faith in the scientiﬁc pro-

cess and the rigor of F.D.A.’s regulatory oversight if

we are to end the pandemic,” the biotech industry’s

trade association pleaded on Thursday, in a letter to

President Trump’s health secretary, Alex M. Azar II

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 48 of 127

48 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 37: Air Visitors to US Face VirusFree Order

https://www.nytimes.com/2021/01/12/health/us-to-require-negative-virus-tests-from-international-

air-passengers.html

Prompt (taken from article):

Before boarding their ﬂights, all international passengers headed to the United States will ﬁrst need

to show proof of a negative coronavirus test, according to a new federal policy going into eﬀect on Jan.

26.

“Testing does not eliminate all risk,” Dr. Robert R. Redﬁeld, the director of the Centers for Disease

Control and Prevention, said in a statement describing the new policy.

“But when combined with a period of staying at home and everyday precautions like wearing masks

and social distancing, it can make travel safer, healthier, and more responsible by reducing spread on

planes, in airports, and at destinations.”

Dr. Redﬁeld is expected to sign the order detailing the new rules on Tuesday.

The new policy requires all air

Output from GPT-4:

passengers, regardless of vaccination status, to get a

test for current infection within the three days be-

fore their ﬂight to the United States departs, and to

provide written documentation of their test results

or proof of having recovered from Covid-19.

Proof of immunization will not be suﬃcient, because

the vaccines have only been shown to prevent serious

illness, said Jason McDonald, a spokesman for the

C.D.C. Vaccinated people may still become infected,

in theory, and transmit the virus on a ﬂight.

The agency will not require further testing in the

three months after a positive test, so long as the

traveler has not had any symptoms. In this situa-

tion, a passenger may travel with documentation of

the positive test result and a letter from a health

care provider or a public health oﬃcial stating that

the traveler now

Actual text from NYTimes:

passengers, regardless of vaccination status, to get a

test for current infection within the three days be-

fore their ﬂight to the United States departs, and to

provide written documentation of their test results

or proof of having recovered from Covid-19.

Proof of immunization will not be suﬃcient, because

the vaccines have only been shown to prevent serious

illness, said Jason McDonald, a spokesman for the

C.D.C. Vaccinated people may still become infected,

in theory, and transmit the virus on a ﬂight.

The agency will not require further testing in the

three months after a positive test, so long as the

traveler has not had any symptoms. In this situa-

tion, a passenger may travel with documentation of

the positive test result and a letter from a health

care provider or a public health oﬃcial stating that

the traveler now

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 49 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 49

Example 38: Shortage of Lab Monkeys Hinders Hunt for Vaccines

https://www.nytimes.com/2021/02/23/business/covid-vaccine-monkeys.html

Prompt (taken from article):

Mark Lewis was desperate to ﬁnd

Output from GPT-4:

monkeys. Millions of human lives, all over the world,

were at risk.

Mr. Lewis, the chief executive of Bioqual, was re-

sponsible for providing lab monkeys to pharmaceuti-

cal companies like Moderna and Johnson & Johnson,

which needed the animals to develop their Covid-19

vaccines. But as the coronavirus swept across the

United States last year, there were few of the spe-

cially bred monkeys to be found anywhere in the

world.

Unable to furnish scientists with monkeys, which

can cost more than $10,000 each, about a dozen

companies were left scrambling for research animals

at the height of the pandemic.

“It’s been nuts, absolutely nuts,” Mr. Lewis said.

The world needs monkeys, whose DNA closely re-

sembles that of humans, to develop Covid-19 vac-

cines. But a global shortage, resulting from the un-

expected demand caused by the pandemic, has been

a major obstacle to research. That has delayed some

drug trials, according to the leading experts on lab

animal supply chains.

The latest shortage has revived talk about creating

a strategic monkey reserve in the United States, an

emergency stockpile similar to those maintained by

the government for oil and grain.

As new variants of the coronavirus threaten to make

the current batch of vaccines obsolete, scientists are

racing to ﬁnd new sources of monkeys, a

Actual text from NYTimes:

monkeys. Millions of human lives, all over the world,

were at stake.

Mr. Lewis, the chief executive of Bioqual, was re-

sponsible for providing lab monkeys to pharmaceuti-

cal companies like Moderna and Johnson & Johnson,

which needed the animals to develop their Covid-19

vaccines. But as the coronavirus swept across the

United States last year, there were few of the spe-

cially bred monkeys to be found anywhere in the

world.

Unable to furnish scientists with monkeys, which

can cost more than $10,000 each, about a dozen

companies were left scrambling for research animals

at the height of the pandemic.

“We lost work because we couldn’t supply the ani-

mals in the time frame,” Mr. Lewis said.

The world needs monkeys, whose DNA closely re-

sembles that of humans, to develop Covid-19 vac-

cines. But a global shortage, resulting from the un-

expected demand caused by the pandemic, has been

exacerbated by a recent ban on the sale of wildlife

from China, the leading supplier of the lab animals.

The latest shortage has revived talk about creating

a strategic monkey reserve in the United States, an

emergency stockpile similar to those maintained by

the government for oil and grain.

As new variants of the coronavirus threaten to make

the current batch of vaccines obsolete, scientists are

racing to ﬁnd new sources of monkeys, a

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 50 of 127

50 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 39: Study Finds a Link Between Air Pollution And Virus Deaths

https://www.nytimes.com/2020/04/07/climate/air-pollution-coronavirus-covid.html

Prompt (taken from article):

WASHINGTON — Coronavirus patients in areas that had high levels of air pollution before the

pandemic are more likely to die

Output from GPT-4:

from the infection than those in cleaner parts of the

country, according to a new nationwide study that

oﬀers the ﬁrst clear link between long-term exposure

to pollution and Covid-19 death rates.

In an analysis of 3,080 counties in the United States,

researchers at the Harvard University T.H. Chan

School of Public Health found that higher levels of

the tiny, dangerous particles in air known as PM 2.5

were associated with higher death rates from the dis-

ease.

For weeks, public health oﬃcials have surmised a

link between dirty air and death or serious illness

from Covid-19, which is caused by the coronavirus.

The Harvard analysis is the ﬁrst nationwide study

to show a statistical link, revealing a “large overlap”

between Covid-19 deaths and other diseases asso-

ciated with long-term exposure to ﬁne particulate

matter.

“The results of this paper suggest that long-term

exposure to air pollution increases vulnerability to

experiencing the most severe Covid-19 outcomes,”

the authors wrote.

The paper found that if Manhattan had lowered its

average particulate matter level by just 1 microgram

per cubic meter over the past 20 years, the bor-

ough would most likely have seen 248 fewer Covid-19

deaths by this point in the outbreak.

The research has not been peer-reviewed and is sub-

ject to revisions, but it oﬀers a powerful new argu-

ment for reducing industrial emissions and other air

pollution, especially in poor communities and those

with large minority populations. These groups are

more likely to live in polluted areas and are among

the most vulnerable to the virus.

The study also could have signiﬁcant implications

for how

Actual text from NYTimes:

from the infection than patients in cleaner parts of

the country, according to a new nationwide study

that oﬀers the ﬁrst clear link between long-term ex-

posure to pollution and Covid-19 death rates.

In an analysis of 3,080 counties in the United States,

researchers at the Harvard University T.H. Chan

School of Public Health found that higher levels of

the tiny, dangerous particles in air known as PM 2.5

were associated with higher death rates from the dis-

ease.

For weeks, public health oﬃcials have surmised a

link between dirty air and death or serious illness

from Covid-19, which is caused by the coronavirus.

The Harvard analysis is the ﬁrst nationwide study

to show a statistical link, revealing a “large overlap”

between Covid-19 deaths and other diseases asso-

ciated with long-term exposure to ﬁne particulate

matter.

“The results of this paper suggest that long-term

exposure to air pollution increases vulnerability to

experiencing the most severe Covid-19 outcomes,”

the authors wrote.

The paper found that if Manhattan had lowered its

average particulate matter level by just a single unit,

or one microgram per cubic meter, over the past 20

years, the borough would most likely have seen 248

fewer Covid-19 deaths by this point in the outbreak.

Over all, the research could have signiﬁcant impli-

cations for how

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 51 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 51

Example 40: Wearing Masks Not Just a Selfless Act Experts Say

https://www.nytimes.com/2020/07/27/health/coronavirus-mask-protection.html

Prompt (taken from article):

Researchers have long known that masks can prevent people from spreading airway germs to oth-

ers — ﬁndings that have driven much of the conversation around these crucial accessories during the

coronavirus pandemic.

But now, as cases continue to rise across the country, experts are

Output from GPT-4:

pointing to an array of evidence suggesting that

masks also protect the people wearing them, lessen-

ing the severity of symptoms, or in some instances,

staving oﬀ infection entirely.

Diﬀerent kinds of masks “block virus to a diﬀerent

degree, but they all block the virus from getting in,”

said Dr. Monica Gandhi, an infectious disease physi-

cian at the University of California, San Francisco.

If any virus particles do breach these barriers, she

said, the disease might still be milder.

Dr. Gandhi and her colleagues make this argument

in a new paper slated to be published in the Journal

of General Internal Medicine. Drawing from animal

experiments and observations of various events dur-

ing the pandemic, they contend that people wearing

face coverings will take in fewer coronavirus parti-

cles, making it easier for their immune systems to

bring any interlopers to

Actual text from NYTimes:

pointing to an array of evidence suggesting that

masks also protect the people wearing them, lessen-

ing the severity of symptoms, or in some instances,

staving oﬀ infection entirely.

Diﬀerent kinds of masks “block virus to a diﬀerent

degree, but they all block the virus from getting in,”

said Dr. Monica Gandhi, an infectious disease physi-

cian at the University of California, San Francisco.

If any virus particles do breach these barriers, she

said, the disease might still be milder.

Dr. Gandhi and her colleagues make this argument

in a new paper slated to be published in the Journal

of General Internal Medicine. Drawing from animal

experiments and observations of various events dur-

ing the pandemic, they contend that people wearing

face coverings will take in fewer coronavirus parti-

cles, making it easier for their immune systems to

bring any interlopers to

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 52 of 127

52 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 41: A Vaccine Protects You but What About Others Thats Where Masks Enter

https://www.nytimes.com/2020/12/08/health/covid-vaccine-mask.html

Prompt (taken from article):

The new Covid-19 vaccines from Pﬁzer and Moderna seem to be remarkably good at preventing

serious illness. But it’s unclear how well they will

Output from GPT-4:

curb the spread of the coronavirus.

That’s because the Pﬁzer and Moderna trials

tracked only how many vaccinated people became

sick with Covid-19. That leaves open the possibility

that some vaccinated people get infected without de-

veloping symptoms, and could then silently transmit

the virus — especially if they come in close contact

with others or stop wearing masks.

If vaccinated people are silent spreaders of the virus,

they may keep it circulating in their communities,

putting unvaccinated people at risk.

“A lot of people are thinking that once they get vac-

cinated, they’re not going to have to wear masks

anymore,” said Michal Tal, an immunologist at

Stanford University. “It’s really going to be criti-

cal for them to know if they have to keep wearing

masks, because they could still be contagious.”

Actual text from NYTimes:

curb the spread of the coronavirus.

That’s because the Pﬁzer and Moderna trials

tracked only how many vaccinated people became

sick with Covid-19. That leaves open the possibility

that some vaccinated people get infected without de-

veloping symptoms, and could then silently transmit

the virus — especially if they come in close contact

with others or stop wearing masks.

If vaccinated people are silent spreaders of the virus,

they may keep it circulating in their communities,

putting unvaccinated people at risk.

“A lot of people are thinking that once they get vac-

cinated, they’re not going to have to wear masks

anymore,” said Michal Tal, an immunologist at

Stanford University. “It’s really going to be criti-

cal for them to know if they have to keep wearing

masks, because they could still be contagious.”

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 53 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 53

Example 42: US Adds 6 Countries Including Nigeria to Restricted Travel List

https://www.nytimes.com/2020/01/31/us/politics/trump-travel-ban.html

Prompt (taken from article):

WASHINGTON — President Trump on Friday added

Output from GPT-4:

six countries to his list of nations facing stringent

travel restrictions, a move that will virtually block

immigration from Africa’s most populous nation,

Nigeria, and from Myanmar, where the Muslim mi-

nority is ﬂeeing genocide.

Beside Nigeria, three other African countries, Er-

itrea, Sudan and Tanzania, will face varying degrees

of restrictions, as will one former Soviet state, Kyr-

gyzstan. Myanmar’s Rohingya Muslims could also

be caught in the crossﬁre.

All six countries have substantial Muslim popula-

tions. The total number of countries now on the

restricted travel list stands at 13.

Immigrant visas, issued to those seeking to live in

the United States, will be banned for Nigeria, Myan-

mar, Eritrea and Kyrgyzstan. The ban will prevent

immigrants from Sudan and Tanzania from moving

to the United States through the diversity visa lot-

tery, which grants green cards to as many as 50,000

people a year.

The proclamation, which President Trump said was

issued to protect American security,will take eﬀect

on Feb. 22. It is likely to infuriate foreign govern-

ments and human rights groups, who have accused

the Trump administration of discriminating against

Muslims and stoking fear among its immigrant com-

munities.

The administration has argued that the ban, en-

acted in 2017 to restrict travel from Muslim-

majority countries, is necessary to ensure that coun-

tries satisfy security requirements for travel into the

United States, or face restrictions until they do.

Actual text from NYTimes:

six countries to his list of nations facing stringent

travel restrictions, a move that will virtually block

immigration from Africa’s most populous nation,

Nigeria, and from Myanmar, where the Muslim mi-

nority is ﬂeeing genocide.

Beside Nigeria, three other African countries, Er-

itrea, Sudan and Tanzania, will face varying degrees

of restrictions, as will one former Soviet state, Kyr-

gyzstan. Myanmar’s Rohingya Muslims could also

be caught in the crossﬁre.

All six countries have substantial Muslim popula-

tions. The total number of countries now on the

restricted travel list stands at 13.

Immigrant visas, issued to those seeking to live in

the United States, will be banned for Nigeria, Myan-

mar, Eritrea and Kyrgyzstan. The ban will also

prevent immigrants from Sudan and Tanzania from

moving to the United States through the diversity

visa lottery, which grants green cards to as many as

50,000 people a year.

The proclamation will take eﬀect on Feb. 22. Immi-

grants who obtain visas before then will still be able

to travel to the United States, oﬃcials said. Non-

immigrant visas, including those for students and

certain temporary workers, as well as visas reserved

for potential employees with specialized skills, will

not be aﬀected by the ban.

Immigrants will be able to apply for waivers from

the restrictions. The administration has said

waivers are issued to those who would experience un-

due hardship if denied entry into the United States,

although the process has been criticized as opaque.

The administration has argued that the ban, en-

acted in 2017 to restrict travel from Muslim-

majority countries, is necessary to ensure that coun-

tries satisfy security requirements for travel into the

United States, or face restrictions until they do.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 54 of 127

54 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 43: Variant Seen In Oregon Has Mutation Like in UK

https://www.nytimes.com/2021/03/05/health/virus-oregon-variant.html

Prompt (taken from article):

Scientists in Oregon have spotted a homegrown version of

Output from GPT-4:

a fast-spreading variant of the coronavirus that ﬁrst

surfaced in Britain — but now it’s combined with a

mutation that may make the variant less susceptible

to vaccines.

The researchers have so far found just a single case

of this formidable combination, but genetic analysis

suggested that the variant had been acquired in the

community and did not arise in the patient.

“We didn’t import this from elsewhere in the world

— it occurred spontaneously,” said Brian O’Roak, a

geneticist at Oregon Health and Science University

who led the work. He and his colleagues participate

in the Centers for Disease Control and Prevention’s

eﬀort to track variants, and they have deposited

their results in databases shared by scientists.

The variant originally identiﬁed in Britain, known

as B.1.1.7, has been spreading rapidly across the

United States, and accounts for at least 2,500 cases

in 46 states. This form of the virus transmits more

eﬀectively than other variants and is thought to be

about 50 percent more transmissible.

The new version that surfaced in Oregon has the

same set of mutations as the B.1.1.7 variant, but also

a mutation — known as E484K, or “Eek” — seen

in variants of the virus circulating in South Africa,

Brazil and New York City.

Lab studies and clinical trials in South Africa indi-

cate that the Eek mutation

Actual text from NYTimes:

a fast-spreading variant of the coronavirus that ﬁrst

surfaced in Britain — but now combined with a mu-

tation that may make the variant less susceptible to

vaccines.

The researchers have so far found just a single case

of this formidable combination, but genetic analysis

suggested that the variant had been acquired in the

community and did not arise in the patient.

“We didn’t import this from elsewhere in the world

— it occurred spontaneously,” said Brian O’Roak, a

geneticist at Oregon Health and Science University

who led the work. He and his colleagues participate

in the Centers for Disease Control and Prevention’s

eﬀort to track variants, and they have deposited

their results in databases shared by scientists.

The variant originally identiﬁed in Britain, called

B.1.1.7, has been spreading rapidly across the

United States, and accounts for at least 2,500 cases

in 46 states. This form of the virus is both more

contagious, and more deadly, than the original ver-

sion, and is expected to account for most infections

in America in a few weeks.

The new version that surfaced in Oregon has the

same backbone, but also a mutation — E484K, or

“Eek” — seen in variants of the virus circulating in

South Africa, Brazil and New York City.

Lab studies and clinical trials in South Africa in-

dicate that the Eek mutation renders the current

vaccines less eﬀective by blunting the body’s im-

mune response. (The vaccines still work, but the

ﬁndings are worrying enough that Pﬁzer-BioNTech

and Moderna have begun testing new versions of

their vaccines designed to defeat the variant found

in South Africa.)

The B.1.1.7 variant

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 55 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 55

Example 44: 21 Men Accuse a Longtime Republican Operative of Online Harassment

https://www.nytimes.com/2021/01/31/us/politics/john-weaver-lincoln-project-harassment.html

Prompt (taken from article):

John Weaver, a longtime Republican strategist and co-founder of the prominent anti-Trump group

the Lincoln Project, has for years sent unsolicited and sexually provocative messages online to young

men, often while suggesting he could help them get work in politics, according to interviews with 21

men who received them.

His solicitations included sending messages to a 14-year-old,

Output from GPT-4:

asking questions about his body while he was still

in high school and then more pointed ones after he

turned 18.

These messages from Mr. Weaver, 61, who helped

run John McCain’s presidential campaigns in 2000

and 2008 and John Kasich’s in 2016, did not lead to

physical encounters except in one consensual case,

and none of the men accused Mr. Weaver of unlaw-

ful conduct. Rather, many of them described feeling

preyed upon by an inﬂuential older man in the ﬁeld

in which they wanted to work, and believing they

had to engage with his lewd messages or lose a pro-

fessional opportunity.

Mr. Weaver sent overt sexual solicitations to at least

10 of the men and, in the most explicit messages,

oﬀered professional and personal assistance in ex-

change for sex. He told one young man he would

“spoil you when we see each other,” according to

messages reviewed by The New York Times.

Actual text from NYTimes:

asking questions about his body while he was still

in high school and then more pointed ones after he

turned 18.

These messages from Mr. Weaver, 61, who helped

run John McCain’s presidential campaigns in 2000

and 2008 and John Kasich’s in 2016, did not lead to

physical encounters except in one consensual case,

and none of the men accused Mr. Weaver of unlaw-

ful conduct. Rather, many of them described feeling

preyed upon by an inﬂuential older man in the ﬁeld

in which they wanted to work, and believing they

had to engage with his repeated messaging or lose a

professional opportunity.

Mr. Weaver sent overt sexual solicitations to at least

10 of the men and, in the most explicit messages,

oﬀered professional and personal assistance in ex-

change for sex. He told one man he would “spoil

you when we see each other,” according to a mes-

sage reviewed by The New York Times.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 56 of 127

56 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 45: 135 Million Face Starvation That Could Double

https://www.nytimes.com/2020/04/22/world/africa/coronavirus-hunger-crisis.html

Prompt (taken from article):

NAIROBI, Kenya — In the largest slum in Kenya’s capital, people desperate to eat set oﬀ a stampede

during a recent giveaway of ﬂour and cooking oil, leaving scores injured and two people dead.

In India, thousands of workers are lining up twice a day for bread and fried vegetables to keep hunger

at bay.

And across Colombia, poor households are hanging red clothing and ﬂags from their windows and

balconies as a sign that they are hungry.

“We don’t have any money, and now we need to survive,” said Pauline Karushi, who lost her job at a

jewelry business in Nairobi, and lives in two rooms with her child and four other relatives. “That means

not eating much.”

The coronavirus pandemic has brought hunger to millions of people around the world. National

lockdowns and social distancing measures are drying up work and incomes, and are likely to disrupt

agricultural production and supply routes — leaving millions to worry how they will get

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 57 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 57

Output from GPT-4:

enough to eat.

Already, 135 million people had been facing acute

food shortages, but now with the pandemic, 130

million more could go hungry in 2020, said Arif Hu-

sain, chief economist at the World Food Program,

a United Nations agency. Altogether, an estimated

265 million people could be pushed to the brink of

starvation by year’s end.

“We’ve never seen anything like this before,” Mr.

Husain said. “It wasn’t a pretty picture to begin

with, but this makes it truly unprecedented and un-

charted territory.”

This hunger crisis, experts say, is global and caused

by a multitude of factors linked to the coronavirus

pandemic and the ensuing interruption of the eco-

nomic order: the sudden loss in income for countless

millions who were already living hand-to-mouth; the

collapse in oil prices; widespread shortages of hard

currency from tourism drying up; overseas work-

ers not having earnings to send home; and ongoing

problems like climate change, violence, population

dislocations and humanitarian disasters.

Already, from Honduras to South Africa to India,

protests and looting have broken out amid frus-

trations from lockdowns and worries about hunger.

With classes canceled, more than 368 million chil-

dren have lost the school meals they depended on.

For those forced to stay home, job loss has been the

price of safety.

“COVID-19 is potentially catastrophic for millions

who are already hanging by a thread,” said Dr.Arif

Husain, chief economist at the World Food Program.

“It is a hammer blow for millions more who can only

eat if they earn a wage. Lockdowns and global eco-

nomic recession have already decimated their nest

eggs. It only gets worse from here.”

The eﬀect is so extensive,the World Food Program

says, that it has had to set a high bar for where it will

be able to intervene. For the ﬁrst time, the agency

is taking into account not just conﬂict and disaster,

but also “economic exposure” — the places where a

local shutdown and the global recession combine to

starve a country of aﬀordable food.

The world has experienced severe hunger crises be-

fore, but those were regional and caused by one fac-

tor or another — extreme weather, economic down-

turns, wars or political in

Actual text from NYTimes:

enough to eat.

The coronavirus has sometimes been called an equal-

izer because it has sickened both rich and poor, but

when it comes to food, the commonality ends. It

is poor people, including large segments of poorer

nations, who are now going hungry and facing the

prospect of starving.

“The coronavirus has been anything but a great

equalizer,” said Asha Jaﬀar, a volunteer who

brought food to families in the Nairobi slum of Kib-

era after the fatal stampede. “It’s been the great

revealer, pulling the curtain back on the class di-

vide and exposing how deeply unequal this country

is.”

Already, 135 million people had been facing acute

food shortages, but now with the pandemic, 130

million more could go hungry in 2020, said Arif Hu-

sain, chief economist at the World Food Program,

a United Nations agency. Altogether, an estimated

265 million people could be pushed to the brink of

starvation by year’s end.

“We’ve never seen anything like this before,” Mr.

Husain said. “It wasn’t a pretty picture to begin

with, but this makes it truly unprecedented and un-

charted territory.”

The world has experienced severe hunger crises be-

fore, but those were regional and caused by one fac-

tor or another — extreme weather, economic down-

turns, wars or political instability.

This hunger crisis, experts say, is global and caused

by a multitude of factors linked to the coronavirus

pandemic and the ensuing interruption of the eco-

nomic order: the sudden loss in income for countless

millions who were already living hand-to-mouth; the

collapse in oil prices; widespread shortages of hard

currency from tourism drying up; overseas work-

ers not having earnings to send home; and ongoing

problems like climate change, violence, population

dislocations and humanitarian disasters.

Already, from Honduras to South Africa to India,

protests and looting have broken out amid frus-

trations from lockdowns and worries about hunger.

With classes shut down, over 368 million children

have lost the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 58 of 127

58 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 46: Rise in Cases Suggests Epidemic Is Pandemic

https://www.nytimes.com/2020/02/02/health/coronavirus-pandemic-china.html

Prompt (taken from article):

The Wuhan coronavirus spreading from China

Output from GPT-4:

is now likely to become a pandemic that circles the

globe, according to many of the world’s leading in-

fectious disease experts.

The prospect is daunting. A pandemic — an on-

going epidemic on two or more continents — may

well have global consequences, despite the extraor-

dinary travel restrictions and quarantines now im-

posed by China and other countries, including the

United States.

Scientists do not yet know how lethal the new coron-

avirus is, however, so there is uncertainty about how

much damage a pandemic might cause. But there

is growing consensus that the pathogen is readily

transmitted between humans.

The Wuhan coronavirus is spreading more like in-

ﬂuenza, which is highly transmissible, than like its

slow-moving viral cousins, SARS and MERS, scien-

tists have

Actual text from NYTimes:

is now likely to become a pandemic that circles the

globe, according to many of the world’s leading in-

fectious disease experts.

The prospect is daunting. A pandemic — an on-

going epidemic on two or more continents — may

well have global consequences, despite the extraor-

dinary travel restrictions and quarantines now im-

posed by China and other countries, including the

United States.

Scientists do not yet know how lethal the new coron-

avirus is, however, so there is uncertainty about how

much damage a pandemic might cause. But there

is growing consensus that the pathogen is readily

transmitted between humans.

The Wuhan coronavirus is spreading more like in-

ﬂuenza, which is highly transmissible, than like its

slow-moving viral cousins, SARS and MERS, scien-

tists have

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 59 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 59

Example 47: Warning of a Pandemic Last Year Was Unheeded

https://www.nytimes.com/2020/03/19/us/politics/trump-coronavirus-outbreak.html

Prompt (taken from article):

WASHINGTON — The outbreak of the respiratory virus began in China and was quickly spread

around the world by air travelers, who ran high fevers. In the United States, it was ﬁrst detected in

Chicago, and 47 days later, the World Health Organization declared a pandemic. By then it was too

late: 110 million Americans were expected to become ill, leading to 7.7 million hospitalized and 586,000

dead.

That scenario, code-named “Crimson Contagion” and imagining an inﬂuenza pandemic, was simulated

by the Trump administration’s Department of Health and Human Services in a series of exercises that

ran from last January to August.

The simulation’s sobering results — contained in a draft report dated October 2019 that has not

previously been reported — drove home just how underfunded, underprepared and uncoordinated the

federal government would be for a life-or-death battle with a virus for which no treatment existed.

The draft report, marked “not to be disclosed,” laid out in stark detail repeated cases

Output from GPT-4:

of ”confusion” in the exercise. Federal agencies jock-

eyed over who was in charge. State oﬃcials and hos-

pitals struggled to ﬁgure out what kind of equipment

was stockpiled or available. Cities and states went

their own ways on school closings.

Many of the potentially deadly consequences of a

failure to address the shortcomings are now playing

out in all-too-real fashion across the country. And

it was hardly the ﬁrst warning for the nation’s lead-

ers. Three times over the past four years the U.S.

government, across two administrations, had grap-

pled in depth with what a pandemic would look like,

identifying likely shortcomings and in some cases

recommending speciﬁc action.

In 2016, the Obama administration produced a com-

prehensive report on the lessons learned by the gov-

ernment from battling Ebola. In January 2017, out-

going Obama administration oﬃcials ran an exten-

sive exercise on responding to a pandemic for incom-

ing senior oﬃcials of the Trump administration.

The full story of why the Trump administration

failed to heed these warnings is still emerging, and

will be the subject of a commission, if Congress gets

its way. But what is clear is that the United States’

response to the coronavirus

Actual text from NYTimes:

of “confusion” in the exercise. Federal agencies jock-

eyed over who was in charge. State oﬃcials and hos-

pitals struggled to ﬁgure out what kind of equipment

was stockpiled or available. Cities and states went

their own ways on school closings.

Many of the potentially deadly consequences of a

failure to address the shortcomings are now playing

out in all-too-real fashion across the country. And

it was hardly the ﬁrst warning for the nation’s lead-

ers. Three times over the past four years the U.S.

government, across two administrations, had grap-

pled in depth with what a pandemic would look like,

identifying likely shortcomings and in some cases

recommending speciﬁc action.

In 2016, the Obama administration produced a com-

prehensive report on the lessons learned by the gov-

ernment from battling Ebola. In January 2017, out-

going Obama administration oﬃcials ran an exten-

sive exercise on responding to a pandemic for incom-

ing senior oﬃcials of the Trump administration.

The full story of the Trump administration’s re-

sponse to the coronavirus

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 60 of 127

60 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 48: Pope in Break From Doctrine Backs SameSex Civil Unions

https://www.nytimes.com/2020/10/21/world/europe/pope-francis-same-sex-civil-unions.html

Prompt (taken from article):

ROME — Pope Francis expressed support for same-sex civil unions in remarks revealed in a

Output from GPT-4:

documentary ﬁlm that premiered on Wednesday, a

signiﬁcant break from his predecessors that staked

out new ground for the church in its recognition of

gay people.

The remarks, coming from the leader of the Roman

Catholic Church, had the potential to shift debates

about the legal status of same-sex couples in na-

tions around the globe and unsettle bishops worried

that the unions threaten what the church considers

traditional marriage — between one man and one

woman.

“What we have to create is a civil union law. That

way they are legally covered,” Francis said in the

documentary, “Francesco,” which premiered at the

Rome Film Festival, reiterating his view that gay

people are children of God. “I stood up for

Actual text from NYTimes:

documentary ﬁlm that premiered on Wednesday, a

signiﬁcant break from his predecessors that staked

out new ground for the church in its recognition of

gay people.

The remarks, coming from the leader of the Roman

Catholic Church, had the potential to shift debates

about the legal status of same-sex couples in na-

tions around the globe and unsettle bishops worried

that the unions threaten what the church considers

traditional marriage — between one man and one

woman.

“What we have to create is a civil union law. That

way they are legally covered,” Francis said in the

documentary, “Francesco,” which debuted at the

Rome Film Festival, reiterating his view that gay

people are children of God. “I stood up for

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 61 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 61

Example 49: President to Push a 6 Trillion Plan Aimed at Growth

https://www.nytimes.com/2021/05/27/business/economy/biden-plan.html

Prompt (taken from article):

WASHINGTON — President Biden will propose a $6 trillion budget on Friday that would take the

United States to its highest sustained levels of federal spending since World War II as he looks

Output from GPT-4:

to fund a sweeping economic agenda that includes

new investments in education, health care and in-

frastructure.

The budget proposal, the ﬁrst of Mr. Biden’s presi-

dency, calls for the federal government to spend $6

trillion in the 2022 ﬁscal year, and for total spend-

ing to rise to $8.2 trillion by 2031. The growth is

driven by Mr. Biden’s two-part agenda to upgrade

the nation’s infrastructure and substantially expand

the social safety net, contained in his American Jobs

Plan and American Families Plan, along with other

planned increases in discretionary spending.

The proposal shows the sweep of Mr. Biden’s ambi-

tions to wield government power to help more Amer-

icans attain the comforts of a middle-class life and to

lift U.S. industry to better compete globally in an

economy the administration believes will be domi-

nated by a race to reduce energy emissions and com-

bat climate change.

Mr. Biden’s plan to fund his agenda by raising taxes

on corporations and high earners would begin to

shrink budget deﬁcits in the 2030s. Administration

oﬃcials have said the jobs and families plans would

be fully oﬀset by tax increases over the course of 15

years, which would then start to reduce the deﬁcit.

The levels of taxation and spending in Mr. Biden’s

plans would expand the federal ﬁscal footprint to

levels rarely seen in the postwar era,to fund invest-

ments that his administration says are crucial to

keeping America competitive. That includes money

for roads, water pipes, broadband internet, electric

vehicle charging stations and advanced manufactur-

ing research. It also envisions funding for aﬀordable

child care, universal prekindergarten,a national paid

leave program and a host of other initiatives.

The budget is simply a proposal and it is up to

Congress to decide on spending levels. But with

Democrats in control of both chambers,Mr. Biden

Actual text from NYTimes:

to fund a sweeping economic agenda that includes

large new investments in education, transportation

and ﬁghting climate change.

Documents obtained by The New York Times show

that the budget request, the ﬁrst of Mr. Biden’s

presidency, calls for total spending to rise to $8.2

trillion by 2031, with deﬁcits running above $1.3

trillion throughout the next decade. The growth is

driven by Mr. Biden’s two-part agenda to upgrade

the nation’s infrastructure and substantially expand

the social safety net, contained in his American Jobs

Plan and American Families Plan, along with other

planned increases in discretionary spending.

The proposal for the 2022 ﬁscal year and ensuing

decade shows the sweep of Mr. Biden’s ambitions

to wield government power to help more Americans

attain the comforts of a middle-class life and to lift

U.S. industry to better compete globally.

The levels of taxation and spending in Mr. Biden’s

plans would expand the federal ﬁscal footprint to

levels rarely seen in the postwar era to fund invest-

ments that his administration says are crucial to

keeping America competitive. That includes money

for roads, water pipes, broadband internet, electric

vehicle charging stations and advanced manufactur-

ing research. But it also envisions funding for aﬀord-

able child care, universal prekindergarten and a na-

tional paid leave program — initiatives that Repub-

licans have balked at bankrolling. Military spending

would also grow, though it would decline as a share

of the economy.

“Now is the time to build the foundation that we’ve

laid, to make bold investments in our families, in

our communities, in our nation,” Mr. Biden told a

crowd in Cleveland on Thursday. “We know from

history that these kinds of investments raise both

the ﬂoor and the ceiling of an economy for every-

body.”

Mr. Biden plans to ﬁnance his agenda by raising

taxes on corporations and high earners, and the doc-

uments show budget deﬁcits shrinking in the 2030s.

Administration oﬃcials have said the jobs and fam-

ilies plans would be fully oﬀset by tax increases over

the course of 15 years, which

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 62 of 127

62 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 50: With Record Deaths and a New Variant Brazil Puts the World on Edge

https://www.nytimes.com/2021/03/03/world/americas/brazil-covid-variant.html

Prompt (taken from article):

RIO DE JANEIRO — Covid-19 has already left a trail of death and despair in

Output from GPT-4:

Brazil, one of the worst in the world. Now, a year

into the pandemic, the country is setting another

wrenching record.

No other nation that experienced such a major out-

break is still grappling with record-setting death

tolls and a health care system on the brink of col-

lapse. Many other hard-hit nations are, instead, tak-

ing tentative steps toward a semblance of normalcy.

But Brazil is battling a more contagious variant that

has trampled one major city and is spreading to oth-

ers, even as Brazilians toss away precautionary mea-

sures that could keep them safe.

On Tuesday, Brazil recorded more than 1,700 Covid-

19 deaths, the highest single-day toll of the

Actual text from NYTimes:

Brazil, one of the worst in the world. Now, a year

into the pandemic, the country is setting another

wrenching record.

No other nation that experienced such a major out-

break is still grappling with record-setting death

tolls and a health care system on the brink of col-

lapse. Many other hard-hit nations are, instead, tak-

ing tentative steps toward a semblance of normalcy.

But Brazil is battling a more contagious variant that

has trampled one major city and is spreading to oth-

ers, even as Brazilians toss away precautionary mea-

sures that could keep them safe.

On Tuesday, Brazil recorded more than 1,700 Covid-

19 deaths, the highest single-day toll of the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 63 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 63

Example 51: Breaches by Russians Pointing To Election Threat Officials Say

https://www.nytimes.com/2020/10/22/us/politics/russia-election-interference-hacks.html

Prompt (taken from article):

WASHINGTON — While senior Trump administration oﬃcials said this week that Iran has been

actively interfering in the presidential election, many intelligence oﬃcials said they remained far more

concerned about Russia, which in recent days has hacked into state and local computer

Output from GPT-4:

networks in breaches that could allow Moscow

broader access to American voting infrastructure.

The discovery of the hacks came as American intelli-

gence agencies, inﬁltrating Russian networks them-

selves, have pieced together details of what they be-

lieve are Russia’s plans to interfere in the presiden-

tial race in its ﬁnal days or immediately after the

election on Nov. 3. Oﬃcials did not make clear

what Russia planned to do, but they said its oper-

ations would be intended to help President Trump,

potentially by exacerbating disputes around the re-

sults, especially if the race is too close to call.

There is no evidence that the Russians have changed

any vote tallies or voter registration information, of-

ﬁcials said. They added that the Russian

Actual text from NYTimes:

networks in breaches that could allow Moscow

broader access to American voting infrastructure.

The discovery of the hacks came as American intelli-

gence agencies, inﬁltrating Russian networks them-

selves, have pieced together details of what they be-

lieve are Russia’s plans to interfere in the presiden-

tial race in its ﬁnal days or immediately after the

election on Nov. 3. Oﬃcials did not make clear

what Russia planned to do, but they said its oper-

ations would be intended to help President Trump,

potentially by exacerbating disputes around the re-

sults, especially if the race is too close to call.

F.B.I. and Homeland Security oﬃcials also an-

nounced on Thursday that Russia’s state hackers

had targeted dozens of state and local governments

and aviation networks starting in September. They

stole data from the computer servers of at least two

unidentiﬁed targets and continued to crawl through

some of the aﬀected networks, the agencies said.

Other oﬃcials said that the targets included some

voting-related systems, and that they may have been

collateral damage in the attacks.

So far, there is no evidence that the Russians have

changed any vote tallies or voter registration infor-

mation, oﬃcials said. They added that the Russian

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 64 of 127

64 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 52: Trump Given Brief in February On Possible Russian Bounties

https://www.nytimes.com/2020/06/29/us/politics/russian-bounty-trump.html

Prompt (taken from article):

American oﬃcials provided a written brieﬁng in late February to President Trump laying out their

conclusion that a Russian military intelligence unit oﬀered and paid bounties to Taliban-linked militants

to kill U.S. and coalition troops in Afghanistan, two

Output from GPT-4:

oﬃcials familiar with the matter said.

The investigation into the suspected Russian covert

operation to incentivize such killings has focused in

part on an April 2019 car bombing that killed three

Marines as one such potential attack, according to

multiple oﬃcials familiar with the matter.

The new information emerged as the White House

tried on Monday to play down the intelligence as-

sessment that Russia sought to encourage and re-

ward killings — including reiterating a claim that

Mr. Trump was never briefed about the matter and

portraying the conclusion as disputed and dubious.

But that stance clashed with the disclosure by two

oﬃcials that the intelligence was included months

ago in Mr. Trump’s President’s Daily Brief docu-

ment — a compilation of the government’s latest se-

crets, reports, and analysis about world events that

is prepared for him to read. One of the oﬃcials said

the item appeared in Mr. Trump’s brief in late Feb-

ruary; the other cited Feb. 27, speciﬁcally.

Moreover, a description of the intelligence assess-

ment that the Russian unit had carried out the

bounties plot was also shared with the British gov-

ernment, whose forces were among those said to

have been targeted, according to a senior British

oﬃcial.

Mr. Trump denied on Sunday that he had been

briefed on the matter, as did the White House press

secretary, Kayleigh McEnany, on Monday. Both

pointed to a statement from the director of national

intelligence, John Ratcliﬀe, who said neither the

president nor the vice president was “ever briefed

on any intelligence alleged by the New York Times

in its reporting yesterday.”

But Ms. McEnany and other administration oﬃcials

demurred when asked whether the intelligence was

included in the

Actual text from NYTimes:

oﬃcials familiar with the matter said.

The investigation into the suspected Russian covert

operation to incentivize such killings has focused in

part on an April 2019 car bombing that killed three

Marines as one such potential attack, according to

multiple oﬃcials familiar with the matter.

The new information emerged as the White House

tried on Monday to play down the intelligence as-

sessment that Russia sought to encourage and re-

ward killings — including reiterating a claim that

Mr. Trump was never briefed about the matter and

portraying the conclusion as disputed and dubious.

But that stance clashed with the disclosure by two

oﬃcials that the intelligence was included months

ago in Mr. Trump’s President’s Daily Brief docu-

ment — a compilation of the government’s latest

secrets and best insights about foreign policy and

national security that is prepared for him to read.

One of the oﬃcials said the item appeared in Mr.

Trump’s brief in late February; the other cited Feb.

27, speciﬁcally.

Moreover, a description of the intelligence assess-

ment that the Russian unit had carried out the

bounties plot was also seen as serious and solid

enough to disseminate more broadly across the intel-

ligence community in a May 4 article in the C.I.A.’s

World Intelligence Review, a classiﬁed compendium

commonly referred to as The Wire, two oﬃcials said.

A National Security Council spokesman declined to

comment on any connection between the Marines’

deaths and the suspected Russian plot. The

White House press secretary, Kayleigh McEnany,

did not answer when pressed by reporters on Mon-

day whether the intelligence was included in the

written President’s Daily Brief, and the National Se-

curity Council spokesman pointed to her comments

when asked later about the February written brief-

ing.

Late Monday, John Ratcliﬀe, the recently conﬁrmed

director of national intelligence,

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 65 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 65

Example 53: Historic Milestone for Woman Steeped in Civil Rights Battles

https://www.nytimes.com/2020/11/07/us/politics/kamala-harris.html

Prompt (taken from article):

From the earliest days of her childhood, Kamala Harris was taught that the road to racial justice was

long.

She spoke often on the campaign trail of those who had come before her, of her parents, immigrants

drawn to the civil rights struggle in the United States — and of the ancestors who had paved the way.

As she took the stage in Texas shortly before the election, Ms. Harris spoke of being singular in her

role but not solitary.

“Yes, sister, sometimes we may be the only one that looks like us walking in that room,” she told

a largely Black audience in Fort Worth. “But the thing we all know is we never walk in those rooms

alone — we are all in that room together.”

With her ascension to the vice presidency, Ms. Harris will become the ﬁrst woman and ﬁrst woman

of color to hold that oﬃce, a milestone for a nation in upheaval, grappling with a damaging history

of racial injustice exposed, yet again, in a divisive election. Ms. Harris, 56, embodies the future of a

country that is growing more racially diverse, even if the person voters picked for the top of the ticket

is a 77-year-old white man.

In her victory speech Saturday, Ms. Harris spoke of her mother and the generations of women of all

races who paved the way for this moment. “While I may be the ﬁrst woman in this oﬃce, I will not

be the last,” she told a cheering and honking audience in Wilmington, Del. “Because every little girl

watching tonight sees that this is a country of possibilities.”

That she has risen higher in the country’s leadership than any woman ever has underscores the

extraordinary arc of her political career. A former San Francisco district attorney, she was elected as

the ﬁrst Black woman to serve as California’s attorney general. When she was elected a United States

senator in

Output from GPT-4:

2016, she became only the second Black woman in

the chamber’s history.

Almost immediately, she made a name for herself in

Washington with her withering prosecutorial style

in Senate hearings, grilling her adversaries in high-

stakes moments that at times went viral.

Yet what also distinguished her was her personal

biography: the daughter of a Jamaican father and

an Indian mother, she was steeped in racial justice

issues from her early years in Oakland and Berkeley,

Calif., and wrote in her memoir of memories of the

chants, shouts and “sea of legs moving about” at

protests. She recalled hearing Shirley Chisholm, the

ﬁrst Black woman to mount a national campaign for

president, speak in 1971 at a Black cultural center

in Berkeley that she frequented as a young

Actual text from NYTimes:

2016, she became only the second Black woman in

the chamber’s history.

Almost immediately, she made a name for herself in

Washington with her withering prosecutorial style

in Senate hearings, grilling her adversaries in high-

stakes moments that at times went viral.

Yet what also distinguished her was her personal bi-

ography: The daughter of a Jamaican father and

Indian mother, she was steeped in racial justice is-

sues from her early years in Oakland and Berkeley,

Calif., and wrote in her memoir of memories of the

chants, shouts and “sea of legs moving about” at

protests. She recalled hearing Shirley Chisholm, the

ﬁrst Black woman to mount a national campaign for

president, speak in 1971 at a Black cultural center

in Berkeley that she frequented as a young

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 66 of 127

66 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 54: For Tech China Deal Could Mean Bigger Losses

https://www.nytimes.com/2020/01/20/business/economy/trump-us-china-deal-micron-trade-war.

html

Prompt (taken from article):

WASHINGTON — Among the

Output from GPT-4:

corporate titans recognized last week by President

Trump during a White House signing ceremony for

his China trade deal was Sanjay Mehrotra, the chief

executive of Micron Technology, whose Idaho semi-

conductor company is at the heart of Mr. Trump’s

trade war.

Micron, which makes memory chips for computers

and smartphones, is precisely the kind of advanced

technology company that the Trump administra-

tion views as crucial to maintaining a competitive

edge over China. After Micron rebuﬀed a 2015

takeover attempt by a Chinese state-owned com-

pany, it watched with disbelief as its innovations

were stolen and copied by a Chinese competitor and

its business was blocked from

Actual text from NYTimes:

corporate titans recognized last week by President

Trump during a White House signing ceremony for

his China trade deal was Sanjay Mehrotra, the chief

executive of Micron Technology, whose Idaho semi-

conductor company is at the heart of Mr. Trump’s

trade war.

Micron, which makes memory chips for computers

and smartphones, is precisely the kind of advanced

technology company that the Trump administra-

tion views as crucial to maintaining a competitive

edge over China. After Micron rebuﬀed a 2015

takeover attempt by a Chinese state-owned com-

pany, it watched with disbelief as its innovations

were stolen and copied by a Chinese competitor and

its business was blocked from

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 67 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 67

Example 55: Scientists Feel Optimistic About Goal of Developing Compact Fusion

Reactor

https://www.nytimes.com/2020/09/29/climate/nuclear-fusion-reactor.html

Prompt (taken from article):

Scientists developing a compact version of a nuclear fusion reactor have shown in

Output from GPT-4:

a series of research papers that it should work, re-

newing hopes that the long-elusive goal of mimicking

the way the sun produces energy might be achieved

and eventually contribute to the ﬁght against cli-

mate change.

Construction of a reactor, called Sparc, which is be-

ing developed by researchers at the Massachusetts

Institute of Technology and a spinoﬀ company,

Commonwealth Fusion Systems, is expected to be-

gin next spring and take three or four years, the

researchers and company oﬃcials said.

Although many signiﬁcant challenges remain, the

company said construction would be followed by

testing and, if successful, building of a power plant

that could use fusion energy to generate electricity,

beginning in the next decade.

This ambitious timetable is far faster than that of

the world’s largest fusion power project, a multina-

tional endeavor in Southern France called ITER, for

International Thermonuclear Experimental Reactor,

which began construction in 2007 and is expected to

generate electricity around 2035.

Fusion, in which lightweight atoms are brought to-

gether at temperatures of tens of millions of degrees

to release energy, has been held out as

Actual text from NYTimes:

a series of research papers that it should work, re-

newing hopes that the long-elusive goal of mimicking

the way the sun produces energy might be achieved

and eventually contribute to the ﬁght against cli-

mate change.

Construction of a reactor, called Sparc, which is be-

ing developed by researchers at the Massachusetts

Institute of Technology and a spinoﬀ company,

Commonwealth Fusion Systems, is expected to be-

gin next spring and take three or four years, the

researchers and company oﬃcials said.

Although many signiﬁcant challenges remain, the

company said construction would be followed by

testing and, if successful, building of a power plant

that could use fusion energy to generate electricity,

beginning in the next decade.

This ambitious timetable is far faster than that of

the world’s largest fusion-power project, a multina-

tional eﬀort in Southern France called ITER, for

International Thermonuclear Experimental Reactor.

That reactor has been under construction since 2013

and, although it is not designed to generate electric-

ity, is expected to produce a fusion reaction by 2035.

Bob Mumgaard, Commonwealth Fusion’s chief ex-

ecutive and one of the company’s founders, said a

goal of the Sparc project was to develop fusion in

time for it to play a role in mitigating global warm-

ing. “We’re really focused on how you can get to

fusion power as quickly as possible,” he said.

Fusion, in which lightweight atoms are brought to-

gether at temperatures of tens of millions of degrees

to release energy, has been held out as

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 68 of 127

68 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 56: Trump Hits Back Firing Witnesses After Acquittal

https://www.nytimes.com/2020/02/07/us/politics/alexander-vindman-gordon-sondland-fired.html

Prompt (taken from article):

WASHINGTON — President Trump wasted little time on Friday opening a campaign of retribution

against those he blames for his impeachment, ﬁring two of the most prominent witnesses in

Output from GPT-4:

the House inquiry against him barely 48 hours after

being acquitted by the Senate.

Emboldened by his victory and determined to strike

back, Mr. Trump ordered Gordon D. Sondland, the

founder of a hotel chain who donated $1 million to

the president’s inaugural committee, recalled from

his post as the United States ambassador to the Eu-

ropean Union on the same day that he had Lt. Col.

Alexander S. Vindman, a decorated Iraq war veteran

on the National Security Council staﬀ, marched out

of the White House by security guards.

The ousters of Mr. Sondland and Colonel Vind-

man — along with Mr. Vindman’s brother, Lt.

Col. Yevgeny Vindman, an Army oﬃcer who also

worked on the National Security Council staﬀ —

may only presage a broader eﬀort to even accounts

with the president’s perceived enemies. In the days

since his acquittal, the president has spoken of those

who “put me through” the impeachment as “evil,”

“corrupt” and “crooked,” while his press secretary

declared that those who hurt the president “should

pay for it.”

“There is no question in the mind of any Ameri-

can why this man’s job is over,” David Pressman,

Colonel Vindman’s lawyer, said in a statement.

“LTC Vindman was asked to leave for telling the

truth. His honor, his commitment to right, fright-

ened the powerful.”

The White House did not respond to a request for

comment on Friday night, but earlier in the day,

Mr. Trump foreshadowed Colonel Vindman’s fate.

“Well, I’m not happy with him,” the president said.

“You think I’m supposed to be happy with him? I’m

not.”

The ﬁrings were the ﬁrst retaliatory steps after the

Senate acquitted Mr. Trump on Wednesday of

charges that he abused his power and obstructed

Congress. The president is said to be weighing other

actions, including against other oﬃcials who testi-

ﬁed in the

Actual text from NYTimes:

the House inquiry against him barely 48 hours after

being acquitted by the Senate.

Emboldened by his victory and determined to strike

back, Mr. Trump ordered Gordon D. Sondland, the

founder of a hotel chain who donated $1 million to

the president’s inaugural committee, recalled from

his post as the ambassador to the European Union

on the same day that Lt. Col. Alexander S. Vind-

man, a decorated Iraq war veteran on the National

Security Council staﬀ, was marched out of the White

House by security guards.

The ousters of Mr. Sondland and Colonel Vindman

— along with Mr. Vindman’s brother, Lt. Col.

Yevgeny Vindman, an Army oﬃcer who also worked

on the National Security Council staﬀ — may only

presage a broader eﬀort to even accounts with the

president’s perceived enemies. In the two days since

his acquittal in the Senate, Mr. Trump has railed

about those who stood against him, calling them

“evil,” “corrupt” and “crooked,” while his press sec-

retary declared that those who hurt the president

“should pay for” it.

Even as he began purging administration oﬃcials

who testiﬁed in the House impeachment inquiry,

Mr. Trump assailed a Democratic senator who he

had hoped would side with him during the trial but

did not and called on the House to “expunge” his

impeachment because he deems it illegitimate.

The ﬂurry of actions and outbursts drew quick con-

demnation from Democrats, who said the president

was demonstrating that he feels unleashed, and com-

plicated the politics of impeachment for moderate

Republicans who stood by him while arguing that

he had learned his lesson and would be more re-

strained in the future.

“There is no question in the mind of any American

why this man’s job is over, why this country now

has one less soldier serving it at the White House,”

David Pressman, Colonel Vindman’s lawyer, said in

a statement. “Lt. Col. Vindman was asked to leave

for telling the truth. His honor, his commitment to

right, frightened the powerful.”

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 69 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 69

Example 57: Officials Rebuke Trump Accusations of Deleted Votes

https://www.nytimes.com/2020/11/12/us/politics/election-officials-contradict-trump.html

Prompt (taken from article):

WASHINGTON — Hours after President Trump repeated a baseless report that a voting machine

system “deleted 2.7 million Trump votes nationwide,” he was directly contradicted by a group of federal,

state and local election oﬃcials, who issued a statement on Thursday declaring ﬂatly that the election

“was the most secure

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 70 of 127

70 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

in American history” and that “there is no evidence”

any voting systems were compromised.

The rebuke, in a statement by a coordinating council

overseeing the integrity of the election, never men-

tioned Mr. Trump by name. But it amounted to

a remarkable corrective to a wave of disinformation

that Mr. Trump has been pushing across his Twitter

feed.

The statement was distributed by the Department

of Homeland Security’s Cybersecurity and Infras-

tructure Security Agency, which is responsible for

helping states secure the voting process. Coming

directly from one of Mr. Trump’s own cabinet agen-

cies, it further isolated the president in his false

claims that widespread fraud cost him the election.

The oﬃcials directly contradicted Mr. Trump’s

claim, declaring, “While we know there are many

unfounded claims and opportunities for misinforma-

tion about the process of our elections, we can assure

you we have the utmost conﬁdence in the security

and integrity of our elections, and you should too.

When you have questions, turn to elections oﬃcials

as trusted voices as they administer elections.”

The statement was signed by the members of the

Election Infrastructure Government Coordinating

Council, which includes top oﬃcials from the Cy-

bersecurity and Infrastructure Security Agency, the

U.S. Election Assistance Commission and secre-

taries of state and state election directors from

around the country. The group also includes repre-

sentatives from the voting machine industry, which

has often been accused of being slow to admit to

technological vulnerabilities in its products.

The statement also noted that all states with close

results have paper records of each vote, allowing the

ability to go back and count each ballot if necessary.

“This is an added beneﬁt for security and resilience.

This process allows for the identiﬁcation and correc-

tion of any mistakes or errors,” it said.

The statement came as Mr. Trump continued to

refuse to concede the election to President-elect

Joseph R. Biden

Actual text from NYTimes:

in American history” and that “there is no evidence”

any voting systems were compromised.

The rebuke, in a statement by a coordinating council

overseeing the voting systems used around the coun-

try, never mentioned Mr. Trump by name. But it

amounted to a remarkable corrective to a wave of

disinformation that Mr. Trump has been pushing

across his Twitter feed.

The statement was distributed by the Department

of Homeland Security’s Cybersecurity and Infras-

tructure Security Agency, which is responsible for

helping states secure the voting process. Coming

directly from one of Mr. Trump’s own cabinet agen-

cies, it further isolated the president in his false

claims that widespread fraud cost him the election.

The statement also came as a previously uniﬁed Re-

publican Party showed signs of cracking on the ques-

tion of whether to keep backing the president.

Across the country, election oﬃcials have said the

vote came oﬀ smoothly, with no reports of systemic

fraud in any state, no sign of foreign interference in

the voting infrastructure and no hardware or soft-

ware failures beyond the episodic glitches that hap-

pen in any election. President-elect Joseph R. Biden

Jr.’s lead in the popular vote has expanded to more

than ﬁve million, and he remains on track to win a

solid victory in the Electoral College.

The group that issued the statement was the

Elections Infrastructure Government Coordinating

Council, which includes top oﬃcials from the cyber-

security agency, the U.S. Election Assistance Com-

mission and secretaries of state and state election

directors from around the country. The group also

includes representatives from the voting machine in-

dustry, which has often been accused of being slow

to admit to technological shortcomings and resistant

to creating paper backups.

“While we know there are many unfounded claims

and opportunities for misinformation about the pro-

cess of our elections, we can assure you we have

the utmost conﬁdence in the security and integrity

of our elections, and you should, too,” the oﬃcials

added in their statement. “When you have ques-

tions, turn to elections oﬃcials as trusted voices as

they administer elections.”

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 71 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 71

Example 58: Post Staff Questioned Report on Biden

https://www.nytimes.com/2020/10/18/business/media/new-york-post-hunter-biden.html

Prompt (taken from article):

The New York Post’s front-page article about Hunter

Output from GPT-4:

Biden on Wednesday was written mostly by a staﬀ

reporter who refused to put his name on it, two Post

employees said.

Bruce Golding, a reporter at the Rupert Murdoch-

owned tabloid since 2007, did not allow his byline to

be used because he had concerns over the article’s

credibility, the two Post employees said, speaking on

the condition of anonymity out of fear of retaliation.

Coming late in a heated presidential campaign, the

article suggested that Joseph R. Biden Jr. had used

his position to enrich his son Hunter when he was

vice president. The Post based the story on photos

and documents the paper said it had taken from

the hard drive of a laptop purportedly belonging to

Hunter

Actual text from NYTimes:

Biden on Wednesday was written mostly by a staﬀ

reporter who refused to put his name on it, two Post

employees said.

Bruce Golding, a reporter at the Rupert Murdoch-

owned tabloid since 2007, did not allow his byline to

be used because he had concerns over the article’s

credibility, the two Post employees said, speaking on

the condition of anonymity out of fear of retaliation.

Coming late in a heated presidential campaign, the

article suggested that Joseph R. Biden Jr. had used

his position to enrich his son Hunter when he was

vice president. The Post based the story on photos

and documents the paper said it had taken from

the hard drive of a laptop purportedly belonging to

Hunter

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 72 of 127

72 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 59: Highly Contagious Variant Is Dominant in New Cases Director of CDC

Warns

https://www.nytimes.com/2021/04/07/us/politics/coronavirus-variants-cdc.html

Prompt (taken from article):

WASHINGTON — A highly infectious variant of the coronavirus that was ﬁrst identiﬁed in Britain

has become the most common

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 73 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 73

Output from GPT-4:

source of new infections in the United States, the

director of the Centers for Disease Control and Pre-

vention said on Wednesday. The worrisome devel-

opment comes as oﬃcials and scientists warn of a

possible fourth surge of cases.

Federal health oﬃcials said in January that the

B.1.1.7 variant, which began surging in Britain in

December and has since slammed Europe, could be-

come the dominant source of coronavirus infections

in the United States, leading to a huge increase in

cases and deaths.

At that point, new cases, hospitalizations and

deaths were at an all-time high. From that peak,

the numbers all fell until late February, according

to a New York Times database. After several weeks

at a plateau, new cases and hospitalizations are in-

creasing again. The average number of new cases

has reached nearly 65,000 a day as of Tuesday, con-

centrated mostly in metro areas in Michigan as well

as in the New York City region. That is an increase

of 19 percent compared with the ﬁgure two weeks

ago.

Dr. Rochelle Walensky, the C.D.C. director, who

warned last week that she felt a sense of “impending

doom,” said on Wednesday that 52 of the agency’s

64 jurisdictions — which include states, some ma-

jor cities and territories — are now reporting cases

of these so-called “variants of concern,” including

B.1.1.7.

The sheer number of people in the United States

who have been infected with the virus — more than

30 million — and the number of people who have

been vaccinated — more than 107 million have re-

ceived at least one dose — should help slow down

the spread of the virus. But the B.1.1.7 variant is

more contagious, more likely to lead to severe illness

and death, and able to partially evade the antibod-

ies made by the immune system after a coronavirus

infection or vaccination.

In addition to spreading more eﬃciently, there is

a concern that the B.1.1.7 variant may also be

associated with an increased risk of death com-

pared with other variants, the C.D.C. has said. The

agency’s studies suggest that vaccines are less ef-

fective against a variant that was ﬁrst identiﬁed in

South Africa and is circulating in the United States,

Actual text from NYTimes:

source of new infections in the United States, the

director of the Centers for Disease Control and Pre-

vention said on Wednesday. The worrisome devel-

opment comes as oﬃcials and scientists warn of a

possible fourth surge of infections.

Federal health oﬃcials said in January that the

B.1.1.7 variant, which began surging in Britain in

December and has since slammed Europe, could be-

come the dominant source of coronavirus infections

in the United States, leading to a huge increase in

cases and deaths.

At that point, new cases, hospitalizations and

deaths were at an all-time high. From that peak, the

numbers all declined until late February, according

to a New York Times database. After several weeks

at a plateau, new cases and hospitalizations are in-

creasing again. The average number of new cases

in the country has reached nearly 65,000 a day as

of Tuesday, concentrated mostly in metro areas in

Michigan as well as in the New York City region.

That is an increase of 19 percent compared with the

ﬁgure two weeks ago.

Dr. Rochelle Walensky, the C.D.C. director, who

warned last week that she felt a recurring sense of

“impending doom,” said on Wednesday that 52 of

the agency’s 64 jurisdictions — which include states,

some major cities and territories — are now report-

ing cases of these so-called “variants of concern,”

including B.1.1.7.

The number of deaths, however, continue to decline

— potentially a sign that mass vaccinations are be-

ginning to protect older Americans and other highly

vulnerable populations.

“These trends are pointing to two clear truths,” Dr.

Walensky said. “One, the virus still has hold on us,

infecting people and putting them in harm’s way,

and we need to remain vigilant. And two, we need to

continue to accelerate our vaccination eﬀorts and to

take the individual responsibility to get vaccinated

when we can.”

B.1.1.7, the ﬁrst variant to come to widespread at-

tention, is about 60 percent more contagious and 67

percent more deadly than the original form of the

coronavirus, according to the most recent estimates.

The C.D.C. has

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 74 of 127

74 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 60: An Outbreak in the Amazon Includes Many Reinfections

https://www.nytimes.com/2021/03/01/health/covid-19-coronavirus-brazil-variant.html

Prompt (taken from article):

In just a matter of weeks, two variants of the coronavirus have become so familiar that you can hear

their inscrutable alphanumeric names regularly uttered on television news.

B.1.1.7, ﬁrst identiﬁed in Britain, has demonstrated the power to spread far and fast. In South Africa,

a mutant called B.1.351 can dodge human antibodies, blunting the eﬀectiveness of some vaccines.

Scientists have also had their eye on a third concerning variant that arose in Brazil, called P.1.

Research had been slower on P.1 since its discovery in late December, leaving scientists unsure of just

how much to worry about it.

“I’ve been holding my breath,” said Bronwyn MacInnis, an epidemiologist at the Broad Institute.

Now three studies oﬀer a sobering history of P.1’s meteoric rise in the Amazonian city of Manaus.

It most likely arose there in November and then fueled a record-breaking spike of coronavirus cases. It

came to dominate the city partly because of an increased contagiousness, the research found.

But it also gained the ability to infect some people who had immunity from previous bouts of Covid-

19. And laboratory experiments suggest that P.1 could weaken the protective eﬀect of a Chinese vaccine

now in use in Brazil.

The new studies have yet to be published in scientiﬁc journals. Their authors caution that ﬁndings

on cells in laboratories do not always translate to the real world, and they’ve only begun to understand

P.1’s behavior.

“The ﬁndings apply to Manaus, but I don’t know if they apply to other places,” said Nuno Faria, a

virologist at Imperial College London who helped lead much of the new research.

But even with the mysteries that remain around P.1, experts said it is a variant to take seriously.

“It’s right to be worried about P.1, and this data gives us the reason why,” said William Hanage, an

epidemiologist at the Harvard T.H. Chan School of Public Health.

P.1 is now spreading across the rest of Brazil and has been found in 24 other countries. In the United

States, the Centers for Disease Control and Prevention has recorded six cases in ﬁve states: Alaska,

Florida,

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 75 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 75

Output from GPT-4:

Maryland, Minnesota and Oklahoma.

To reduce the risks of P.1 outbreaks and reinfections,

Dr. Faria said it was important to double down on

every measure we have to slow the spread of the

coronavirus. Masks and social distancing can work

against P.1. And vaccination can help drive down its

transmission and protect those who do get infected

from severe disease.

“The ultimate message is that you need to step up

all the vaccination eﬀorts as soon as possible,” he

said. “You need to be one step ahead of the virus.”

Dr. Faria and his colleagues started tracking the

coronavirus when it exploded in Brazil last spring.

Manaus, a city of 2 million in the Brazilian Amazon,

was hit particularly hard. At its springtime peak,

the city’s cemeteries were overwhelmed by the bod-

ies of the dead.

But after a peak in late April, Manaus seemed to

have gotten past the worst of the pandemic. Some

scientists thought that the drop in cases might be a

sign that Manaus had reached herd immunity.

Dr. Faria and his colleagues

Actual text from NYTimes:

Maryland, Minnesota and Oklahoma.

To reduce the risks of P.1 outbreaks and reinfections,

Dr. Faria said it was important to double down on

every measure we have to slow the spread of the

coronavirus. Masks and social distancing can work

against P.1. And vaccination can help drive down its

transmission and protect those who do get infected

from severe disease.

“The ultimate message is that you need to step up

all the vaccination eﬀorts as soon as possible,” he

said. “You need to be one step ahead of the virus.”

Dr. Faria and his colleagues started tracking the

coronavirus when it exploded in Brazil last spring.

Manaus, a city of two million in the Brazilian Ama-

zon, was hit particularly hard. At its springtime

peak, the cemeteries of Manaus were overwhelmed

by the bodies of the dead.

But after a peak in late April, Manaus seemed to

have gotten past the worst of the pandemic. Some

scientists thought that the drop meant Manaus had

gained herd immunity.

Dr.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 76 of 127

76 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 61: Trump to Halt Worker Visas Through 2020

https://www.nytimes.com/2020/06/22/us/politics/trump-h1b-work-visas.html

Prompt (taken from article):

WASHINGTON — President Trump on Monday temporarily suspended new work visas and barred

hundreds of thousands of foreigners from seeking employment in the United States, part of a broad

eﬀort to limit the

Output from GPT-4:

entry of immigrants into the country.

In a sweeping order, which will be in place at least

until the end of the year, Mr. Trump blocked visas

for a wide variety of jobs, including those for com-

puter programmers and other skilled workers who

enter the country under the H-1B visa, as well as

those for seasonal workers in the hospitality indus-

try, students on work-study summer programs and

au pairs who arrive under other auspices.

The order also restricts the ability of American com-

panies with global operations and international com-

panies with U.S. branches to transfer foreign ex-

ecutives and other employees to the United States

for months or yearslong stints. And it blocks the

spouses of foreigners who are employed at compa-

nies in the United States.

Oﬃcials said the ban, combined with extending a

pause on issuing green cards, would keep as many

as 525,000 foreign workers out of the country for the

rest of the year.

Actual text from NYTimes:

entry of immigrants into the country.

In a sweeping order, which will be in place at least

until the end of the year, Mr. Trump blocked visas

for a wide variety of jobs, including those for com-

puter programmers and other skilled workers who

enter the country under the H-1B visa, as well as

those for seasonal workers in the hospitality indus-

try, students on work-study summer programs and

au pairs who arrive under other auspices.

The order also restricts the ability of American com-

panies with global operations and international com-

panies with U.S. branches to transfer foreign ex-

ecutives and other employees to the United States

for months or yearslong stints. And it blocks the

spouses of foreigners who are employed at compa-

nies in the United States.

Oﬃcials said the ban on worker visas, combined

with extending restrictions on the issuance of new

green cards, would keep as many as 525,000 foreign

workers out of the country for the rest of the year.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 77 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 77

Example 62: America Is Facing 5 Epic Crises at Once

https://www.nytimes.com/2020/06/25/opinion/us-coronavirus-protests.html

Prompt (taken from article):

There are ﬁve gigantic changes happening in America right now. The ﬁrst is that we are losing the

ﬁght against Covid-19. Our behavior doesn’t have anything to do with the reality around us. We just

got tired so we’re giving up.

Second, all Americans, but especially

Output from GPT-4:

white Americans, are undergoing a rapid education

on the burdens African-Americans carry every day.

This education is continuing, but already public

opinion is shifting with astonishing speed.

Third, we’re in the middle of a political realignment.

The American public is vehemently rejecting Don-

ald Trump’s Republican Party. The most telling

sign is that the party has even given up on itself, a

personality cult whose cult leader is over.

Fourth, a quasi-religion is seeking control of Amer-

ica’s cultural institutions. The acolytes of this quasi-

religion, Social Justice, hew to a simplifying ideol-

ogy: History is essentially a power struggle between

groups, some of which are oppressors and others

of which are oppressed. Viewpoints are not explo-

rations of truth; they are weapons that dominant

groups use to maintain their place in the power

Actual text from NYTimes:

white Americans, are undergoing a rapid education

on the burdens African-Americans carry every day.

This education is continuing, but already public

opinion is shifting with astonishing speed.

Third, we’re in the middle of a political realignment.

The American public is vehemently rejecting Don-

ald Trump’s Republican Party. The most telling

sign is that the party has even given up on itself, a

personality cult whose cult leader is over.

Fourth, a quasi-religion is seeking control of Amer-

ica’s cultural institutions. The acolytes of this quasi-

religion, Social Justice, hew to a simplifying ideol-

ogy: History is essentially a power struggle between

groups, some of which are oppressors and others

of which are oppressed. Viewpoints are not explo-

rations of truth; they are weapons that dominant

groups use to maintain their place in the power

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 78 of 127

78 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 63: Bottoms Up Maybe You Had Better Not

https://www.nytimes.com/2020/07/10/well/eat/should-we-be-drinking-less.html

Prompt (taken from article):

Can a daily drink or two lead to better health?

For many years, the federal government’s inﬂuential dietary guidelines implied as much, saying there

was evidence

Output from GPT-4:

that moderate drinking could lower the risk of heart

disease and reduce mortality.

But now a committee of scientists that is helping to

update the latest edition of the Dietary Guidelines

for Americans is taking a harder stance on alcohol.

The committee said in a recent conference call that

it plans to recommend that men and women who

drink limit themselves to a single serving of wine,

beer or liquor per day. Do not drink because you

think it will make you healthier, the committee says:

It won’t. And it maintains that drinking less is gen-

erally better for health than drinking more.

That message is a departure from previous guide-

lines, which since 1980 have deﬁned “moderate”

drinking as up to two drinks a day for men and one

for women.

Actual text from NYTimes:

that moderate drinking could lower the risk of heart

disease and reduce mortality.

But now a committee of scientists that is helping to

update the latest edition of the Dietary Guidelines

for Americans is taking a harder stance on alcohol.

The committee said in a recent conference call that

it plans to recommend that men and women who

drink limit themselves to a single serving of wine,

beer or liquor per day. Do not drink because you

think it will make you healthier, the committee says:

It won’t. And it maintains that drinking less is gen-

erally better for health than drinking more.

That message is a departure from previous guide-

lines, which since 1980 have deﬁned “moderate”

drinking as up to two drinks a day for men and one

for women.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 79 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 79

Example 64: Partners in Misinformation

https://www.nytimes.com/2020/11/20/business/media/steve-bannon-china.html

Prompt (taken from article):

Dr. Li-Meng Yan wanted to remain anonymous. It was mid-January, and Dr. Yan, a researcher

in Hong Kong, had been hearing rumors about a dangerous new virus in mainland China that the

government was playing down. Terriﬁed for her personal safety and career, she reached out to her

favorite Chinese YouTube host, known for criticizing the Chinese government.

Within days, the host was telling his 100,000 followers that the coronavirus had been deliberately

released by the Chinese Communist Party. He wouldn’t name the whistle-blower, he said, because

oﬃcials could make the person “disappear.”

By September, Dr. Yan had abandoned caution. She appeared in the United States on Fox News

making the unsubstantiated claim to millions that the coronavirus was a bio-weapon manufactured by

China.

Overnight, Dr. Yan became a right-wing media sensation, with top advisers to President Trump

and conservative pundits hailing her as a hero. Nearly as quickly, her interview was labeled on social

media as containing “false information,” while scientists rejected her research as a polemic dressed up

in jargon.

Her evolution was the product of a

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 80 of 127

80 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

collaboration between two separate but increasingly

allied groups that peddle misinformation: a small

but active corner of the Chinese diaspora and the

highly inﬂuential far right in the United States.

Each saw an opportunity in the pandemic to push

its agenda. For the diaspora, Dr. Yan and her un-

founded claims provided a cudgel for those intent

on bringing down China’s government. For Ameri-

can conservatives, they played into rising anti-China

sentiments and distracted from the Trump adminis-

tration’s bungled handling of the outbreak.

Both sides took advantage of the lack of trans-

parency in China, where the government has re-

fused to share samples of the virus and has resisted a

transparent, independent investigation into its ori-

gins. And both used the dearth of information to

sow fear and distrust of China, scientists and per-

ceived enemies within the United States.

Dr. Yan’s trajectory was carefully crafted by Guo

Wengui, a fugitive Chinese billionaire, and Steve

Bannon, a former adviser to Mr. Trump. They

put Dr. Yan on a plane to the United States, gave

her a place to stay, coached her on media appear-

ances and helped her secure interviews with popular

conservative television hosts like Tucker Carlson and

Lou Dobbs, who have shows on Fox. They nurtured

her seemingly deep belief that the virus was genet-

ically engineered, uncritically embracing what she

provided as proof.

The media outlets that cater to the Chinese diaspora

— a jumble of

Actual text from NYTimes:

collaboration between two separate but increasingly

allied groups that peddle misinformation: a small

but active corner of the Chinese diaspora and the

highly inﬂuential far right in the United States.

Each saw an opportunity in the pandemic to push

its agenda. For the diaspora, Dr. Yan and her un-

founded claims provided a cudgel for those intent

on bringing down China’s government. For Ameri-

can conservatives, they played to rising anti-Chinese

sentiment and distracted from the Trump adminis-

tration’s bungled handling of the outbreak.

Both sides took advantage of the dearth of infor-

mation coming out of China, where the government

has refused to share samples of the virus and has re-

sisted a transparent, independent investigation. Its

initial cover-up of the outbreak has further fueled

suspicion about the origins of the virus.

An overwhelming body of evidence shows that the

virus almost certainly originated in an animal, most

likely a bat, before evolving to make the leap into

humans. While U.S. intelligence agencies have not

ruled out the possibility of a lab leak, they have not

found any proof so far to back up that theory.

Dr. Yan’s trajectory was carefully crafted by Guo

Wengui, a fugitive Chinese billionaire, and Stephen

K. Bannon, a former adviser to Mr. Trump.

They put Dr. Yan on a plane to the United States,

gave her a place to stay, coached her on media ap-

pearances and helped her secure interviews with

popular conservative television hosts like Tucker

Carlson and Lou Dobbs, who have shows on Fox.

They nurtured her seemingly deep belief that the

virus was genetically engineered, uncritically em-

bracing what she provided as proof.

“I said from Day 1, there’s no conspiracies,” Mr.

Bannon said in an interview. “But there are also no

coincidences.”

Mr. Bannon noted that unlike Dr. Yan, he did

not believe the Chinese government “purposely did

this.” But he has pushed the theory about an acci-

dental leak of risky laboratory research and has been

intent on creating a debate about the new coron-

avirus’s origins.

“Dr. Yan is one small voice, but at least she’s a

voice,” he said.

The media outlets that cater to the Chinese diaspora

— a jumble of

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 81 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 81

Example 65: Industry Ties Pose Possible Conflicts for Scientist Leading Vaccine Team

https://www.nytimes.com/2020/05/20/health/coronavirus-vaccine-czar.html

Prompt (taken from article):

The chief scientist brought on to lead the Trump administration’s vaccine eﬀorts has spent the last

several days trying to

Output from GPT-4:

disentangle pieces of his stock portfolio and his in-

tricate ties to big pharmaceutical interests, as critics

point to the potential for signiﬁcant conﬂicts of in-

terest.

The scientist, Moncef Slaoui, is a venture capitalist

and a former long-time executive at GlaxoSmithK-

line. Most recently, he sat on the board of Moderna,

a Cambridge, Mass., biotechnology ﬁrm with a $30

billion valuation that is pursuing a coronavirus vac-

cine. He resigned when President Trump named him

last Thursday to the new post as chief adviser for

Operation Warp Speed, the federal drive for coron-

avirus vaccines and treatments.

Just days into his job, the extent of Dr. Slaoui’s

ﬁnancial interests in drug companies has begun to

emerge: The value of his stock holdings in Moderna

jumped nearly $2.4 million, to $12.4 million when

the company released preliminary, partial data from

an early phase of its candidate vaccine trial that

helped send the markets soaring on Monday.

Dr. Slaoui sold his shares on Tuesday, and the

administration said he would donate the increased

value to cancer research.

But the Moderna stock is just one piece of his phar-

maceutical portfolio, much of which is not public.

Some ethics and ﬁnancial securities experts have

voiced concerns about the arrangement Dr. Slaoui

has with the administration. He is not a govern-

ment employee, but is instead a contractor, which

exempts him from federal disclosure rules that would

require him to list his outside positions, stock hold-

ings and other potential conﬂicts. And the contract

position is paid, meaning he is earning income on

top of his investments.

The revelations about Dr. Slaoui’s ﬁnancial inter-

ests add to the ethical questions surrounding the

Trump administration’s vaccine eﬀort, which has

awarded billions of dollars in no-bid contracts to

vaccine companies, including Moderna. Several of

the companies, including Moderna and Johnson &

Johnson, have said they would sell their vaccines

at cost during the pandemic, but have not speciﬁed

what they will charge afterward.

Dr. Slaoui

Actual text from NYTimes:

disentangle pieces of his stock portfolio and his in-

tricate ties to big pharmaceutical interests, as critics

point to the potential for signiﬁcant conﬂicts of in-

terest.

The scientist, Moncef Slaoui, is a venture capitalist

and a former longtime executive at GlaxoSmithK-

line. Most recently, he sat on the board of Moderna,

a Cambridge, Mass., biotechnology ﬁrm with a $30

billion valuation that is pursuing a coronavirus vac-

cine. He resigned when President Trump named him

last Thursday to the new post as chief adviser for

Operation Warp Speed, the federal drive for coron-

avirus vaccines and treatments.

Just days into his job, the extent of Dr. Slaoui’s

ﬁnancial interests in drug companies has begun to

emerge: The value of his stock holdings in Moderna

jumped nearly $2.4 million, to $12.4 million when

the company released preliminary, partial data from

an early phase of its candidate vaccine trial that

helped send the markets soaring on Monday.

Dr. Slaoui sold his shares on Tuesday, and the

administration said he would donate the increased

value to cancer research.

But the Moderna stock is just one piece of his phar-

maceutical portfolio, much of which is not pub-

lic. And some ethics and ﬁnancial securities ex-

perts have voiced concerns about the arrangement

Dr. Slaoui struck with the administration.

In agreeing to accept the position, Dr. Slaoui did

not come on board as a government employee. In-

stead, he is on a contract, receiving $1 for his service.

That leaves him exempt from federal disclosure rules

that would require him to list his outside positions,

stock holdings and other potential conﬂicts. And

the contract position is

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 82 of 127

82 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 66: Johnson & Johnson Shots Halted In US Over Rare Clotting Effect

https://www.nytimes.com/2021/04/13/us/politics/johnson-johnson-vaccine-blood-clots-fda-cdc.

html

Prompt (taken from article):

WASHINGTON — Injections of Johnson & Johnson’s coronavirus vaccine

Output from GPT-4:

came to a sudden halt across the country on Tuesday

after federal health agencies called for a pause in the

vaccine’s use as they examine a rare blood-clotting

disorder that emerged in six recipients.

All six were women between the ages of 18 and 48,

and all developed the illness within one to three

weeks of vaccination. One woman in Virginia died,

and a second woman in Nebraska has been hospital-

ized in critical condition.

Nearly seven million people in the United States

have received Johnson & Johnson shots so far, and

roughly nine million more doses have been shipped

out to the states, according to data from the Centers

for Disease Control and Prevention.

Scientists with the F.D.A. and C.D.C. will jointly

examine possible links between the vaccine and the

disorder and determine whether the F.D.A. should

continue to authorize use of the vaccine for all adults

or limit the authorization. An emergency meeting

of the C.D.C.’s outside advisory committee has been

scheduled for Wednesday.

In the meantime, the F.D.A. is recommending that

states pause the use of the Johnson & Johnson vac-

cine. States and other jurisdictions administering

the vaccine should follow that guidance, said Dr.

Anne Schuchat, principal deputy director of the

C.D.C., and Dr. Peter Marks, director of the Center

for Biologics Evaluation and Research at the F.D.A.

“We are recommending a pause in the use of

this vaccine out of an abundance of caution,” Dr.

Schuchat and Dr. Marks said in a joint statement.

“Right now, these adverse events appear to be ex-

tremely rare.”

Actual text from NYTimes:

came to a sudden halt across the country on Tuesday

after federal health agencies called for a pause in the

vaccine’s use as they examine a rare blood-clotting

disorder that emerged in six recipients.

All six were women between the ages of 18 and 48,

and all developed the illness within one to three

weeks of vaccination. One woman in Virginia died,

and a second woman in Nebraska has been hospital-

ized in critical condition.

More than seven million people in the United States

have received Johnson & Johnson shots so far, and

another 10 million doses have been shipped out to

the states, according to data from the Centers for

Disease Control and Prevention.

“We are recommending a pause in the use of this

vaccine out of an abundance of caution,” Dr. Pe-

ter Marks, the director of the Food and Drug Ad-

ministration’s Center for Biologics Evaluation and

Research, and Dr. Anne Schuchat, the principal

deputy director of the C.D.C., said in a joint state-

ment. “Right now, these adverse events appear to

be extremely rare.”

While they framed the move as a recommendation

to health practitioners, the impact was immediate.

By Tuesday evening, every state, the District of

Columbia and Puerto Rico had announced a pause

in Johnson & Johnson vaccine injections.

The same went for the U.S. military, federally run

vaccination sites, and CVS and Walgreens, two

pharmacy giants that participate in the federal pro-

gram, oﬃcials said. Rite Aid, Walmart and Publix

also announced that they had paused Johnson &

Johnson injections.

Beyond American shores, Johnson & Johnson said

it would delay the rollout of its vaccine in Europe,

where several countries were poised to start admin-

istering it this week. South Africa, devastated by a

more contagious variant of the virus that emerged

there, also suspended use of the vaccine

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 83 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 83

Example 67: Stimulus Bill Includes 86 Billion Bailout for Failing Union Pension Plans

https://www.nytimes.com/2021/03/07/business/dealbook/bailout-pensions-stimulus.html

Prompt (taken from article):

Tucked inside the $1.9 trillion stimulus

Output from GPT-4:

bill that cleared the Senate on Saturday is an $86

billion aid package that has nothing to do with the

pandemic.

Rather, the $86 billion is a taxpayer bailout for

about 185 union pension plans that are so close to

collapse that without the rescue, more than a mil-

lion retired truck drivers, retail clerks, builders and

others could be forced to forgo retirement income.

The bailout targets multiemployer pension plans,

which bring groups of companies together with a

union to provide guaranteed beneﬁts. All told,

about 1,400 of the plans cover about 10.7 million

active and retired workers, often in ﬁelds like con-

struction or entertainment where the workers move

from job to job. As the workforces have aged, and

as fewer young workers have joined unions, many of

the plans have run out of money. The trend pre-

dates the pandemic and is a result of fading union

power and industry deregulation.

The provision in the stimulus package would give

the weakest plans enough money to pay hundreds

of thousands of retirees — a number that will grow

in the future — their full pensions for the next 30

years. It does not require the plans to pay back the

bailout, freeze accruals or to end the practices that

led to their current distress, which

Actual text from NYTimes:

bill that cleared the Senate on Saturday is an $86

billion aid package that has nothing to do with the

pandemic.

Rather, the $86 billion is a taxpayer bailout for

about 185 union pension plans that are so close to

collapse that without the rescue, more than a mil-

lion retired truck drivers, retail clerks, builders and

others could be forced to forgo retirement income.

The bailout targets multiemployer pension plans,

which bring groups of companies together with a

union to provide guaranteed beneﬁts. All told,

about 1,400 of the plans cover about 10.7 million

active and retired workers, often in ﬁelds like con-

struction or entertainment where the workers move

from job to job. As the work force ages, an alarm-

ing number of the plans are running out of money.

The trend predated the pandemic and is a result of

fading unions, serial bankruptcies and the misplaced

hope that investment income would foot most of the

bill so that employers and workers wouldn’t have to.

Both the House and Senate stimulus measures would

give the weakest plans enough money to pay hun-

dreds of thousands of retirees — a number that will

grow in the future — their full pensions for the next

30 years. The provision does not require the plans

to pay back the bailout, freeze accruals or to end the

practices that led to their current distress, which

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 84 of 127

84 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 68: Johnson & Johnson Expects Results Soon On a OneShot Vaccine

https://www.nytimes.com/2021/01/13/health/covid-vaccine-johnson-johnson.html

Prompt (taken from article):

Johnson & Johnson expects to release critical results from its Covid-19 vaccine trial in as little as two

weeks — a potential boon in the eﬀort to protect Americans from the coronavirus —

Output from GPT-4:

but most likely won’t be able to provide as many

doses this spring as it promised the federal govern-

ment because of unanticipated manufacturing de-

lays.

If the vaccine can safely protect people from the

coronavirus, as some outside scientists are increas-

ingly conﬁdent it will, it would oﬀer big advan-

tages over the two vaccines authorized in the United

States. Unlike those products, which require two

doses, Johnson & Johnson’s could need just one,

greatly simplifying logistics for local health depart-

ments and clinics struggling to get shots in arms.

Its vaccine can also stay stable in a refrigerator for

months, whereas the others have to be frozen.

But the encouraging prospect of a third eﬀective

vaccine is tempered by apparent lags in the com-

pany’s production. In the company’s $1 billion con-

tract signed with the federal government in August,

Johnson & Johnson pledged to have 12 million doses

of its vaccine ready by the end of February, ramping

up to a total of 100 million doses by the end of June.

Federal oﬃcials have been told that the company has

fallen as much as two months behind the original

production schedule and won’t catch up until the

end of April, when it was supposed to have delivered

more than 60 million doses, according to two people

familiar with the situation who were not authorized

to discuss it publicly.

Despite the delays, the company said it was conﬁ-

dent it could deliver 100 million doses by the end

of June. When federal oﬃcials announced John-

son & Johnson’s contract for 100 million doses last

summer, they suggested that the doses would all be

available by the end of

Actual text from NYTimes:

but most likely won’t be able to provide as many

doses this spring as it promised the federal govern-

ment because of unanticipated manufacturing de-

lays.

If the vaccine can strongly protect people against

Covid-19, as some outside scientists expect, it would

oﬀer big advantages over the two vaccines authorized

in the United States. Unlike those products, which

require two doses, Johnson & Johnson’s could need

just one, greatly simplifying logistics for local health

departments and clinics struggling to get shots in

arms. What’s more, its vaccine can stay stable in a

refrigerator for months, whereas the others have to

be frozen.

But the encouraging prospect of a third eﬀective

vaccine is tempered by apparent lags in the com-

pany’s production. In the company’s $1 billion con-

tract signed with the federal government in August,

Johnson & Johnson pledged to have 12 million doses

of its vaccine ready by the end of February, ramping

up to a total of 100 million doses by the end of June.

Federal oﬃcials have been told that the company has

fallen as much as two months behind the original

production schedule and won’t catch up until the

end of April, when it was supposed to have delivered

more than 60 million doses, according to two people

familiar with the situation who were not authorized

to discuss it publicly.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 85 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 85

Example 69: Chance of Catching Covid From Surfaces Is Low

https://www.nytimes.com/2021/04/08/health/coronavirus-hygiene-cleaning-surfaces.html

Prompt (taken from article):

When the coronavirus began to spread in the United States last spring, many experts warned of the

danger

Output from GPT-4:

posed by surfaces. Researchers reported that the

virus could survive for days on plastic or stainless

steel, and the Centers for Disease Control and Pre-

vention advised that if someone touched one of these

contaminated surfaces — and then touched their

eyes, nose or mouth — they could become infected.

Americans responded in kind, wiping down gro-

ceries, quarantining mail and clearing drugstore

shelves of Clorox Wipes. Facebook closed two of

its oﬃces for a “deep cleaning.” New York’s Metro-

politan Transportation Authority began disinfecting

subway cars every night.

But the era of “hygiene theater” may have come to

an unoﬃcial end this week, when the C.D.C. up-

dated its surface cleaning guidelines and noted that

the risk of contracting the virus from touching a

contaminated surface was less than 1 in 10,000.

“People can be aﬀected with the virus that causes

Covid-19 through contact with contaminated sur-

faces and objects,” Dr. Rochelle Walensky, the di-

rector of

Actual text from NYTimes:

posed by surfaces. Researchers reported that the

virus could survive for days on plastic or stainless

steel, and the Centers for Disease Control and Pre-

vention advised that if someone touched one of these

contaminated surfaces — and then touched their

eyes, nose or mouth — they could become infected.

Americans responded in kind, wiping down gro-

ceries, quarantining mail and clearing drugstore

shelves of Clorox wipes. Facebook closed two of

its oﬃces for a “deep cleaning.” New York’s Metro-

politan Transportation Authority began disinfecting

subway cars every night.

But the era of “hygiene theater” may have come to

an unoﬃcial end this week, when the C.D.C. up-

dated its surface cleaning guidelines and noted that

the risk of contracting the virus from touching a

contaminated surface was less than 1 in 10,000.

“People can be aﬀected with the virus that causes

Covid-19 through contact with contaminated sur-

faces and objects,” Dr. Rochelle Walensky, the di-

rector of

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 86 of 127

86 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 70: Health Worker Hospitalized After Vaccine

https://www.nytimes.com/2020/12/16/health/covid-pfizer-vaccine-allergic-reaction.html

Prompt (taken from article):

Two health care workers at the same hospital in Alaska developed concerning reactions just

Output from GPT-4:

minutes after receiving Pﬁzer’s coronavirus vaccine

this week, including one staﬀ member who was ad-

mitted to the hospital. Both of them are expected

to recover, a top oﬃcial said on Wednesday.

The ﬁrst worker, a middle-aged woman who had

no history of allergies, had an anaphylactic reaction

that began 10 minutes after receiving the vaccine at

Bartlett Regional Hospital in Juneau on Tuesday, a

hospital oﬃcial said. She experienced a rash over

her face and torso, shortness of breath and an ele-

vated heart rate.

Dr. Lindy Jones, the hospital’s emergency depart-

ment medical director, said the worker was ﬁrst

given a shot of epinephrine, a standard treatment

for severe allergic reactions. Her symptoms sub-

sided but then re-emerged, and she was treated with

steroids and an epinephrine drip.

When doctors tried to stop the drip, her symptoms

re-emerged yet again, so the woman was moved to

the intensive care unit, observed throughout the

night, then weaned oﬀ the drip early Wednesday

morning, Dr. Jones said.

The second worker received his shot on Wednesday

and developed eye puﬃness, light-headedness and a

scratchy throat 10 minutes after the injection, the

hospital said in a statement. He was taken to the

emergency room and treated with epinephrine, Pep-

cid and Benadryl, although hospital oﬃcials said he

was not considered to have had anaphylaxis. The

worker was back to normal within an hour and re-

leased.

The hospital,

Actual text from NYTimes:

minutes after receiving Pﬁzer’s coronavirus vaccine

this week, including one staﬀ member who was to

remain hospitalized until Thursday.

Health oﬃcials said that the cases would not dis-

rupt their vaccine rollout plans and that they were

sharing the information for the sake of transparency.

The ﬁrst worker, a middle-aged woman who had

no history of allergies, had an anaphylactic reaction

that began 10 minutes after receiving the vaccine at

Bartlett Regional Hospital in Juneau on Tuesday, a

hospital oﬃcial said. She experienced a rash over

her face and torso, shortness of breath and an ele-

vated heart rate.

Dr. Lindy Jones, the hospital’s emergency depart-

ment medical director, said the worker was ﬁrst

given a shot of epinephrine, a standard treatment

for severe allergic reactions. Her symptoms sub-

sided but then re-emerged, and she was treated with

steroids and an epinephrine drip.

When doctors tried to stop the drip, her symptoms

re-emerged yet again, so the woman was moved to

the intensive care unit, observed throughout the

night, then weaned oﬀ the drip early Wednesday

morning, Dr. Jones said.

Dr. Jones had said earlier Wednesday that the

woman was set to be discharged in the evening, but

the hospital said late Wednesday that she was re-

maining another night.

The second worker received his shot on Wednesday

and developed eye puﬃness, lightheadedness and a

scratchy throat 10 minutes after the injection, the

hospital said in a statement. He was taken to the

emergency room and treated with epinephrine, Pep-

cid and Benadryl, although the hospital said the re-

action was not considered anaphylaxis. The worker

was back to normal within an hour and released.

The hospital,

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 87 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 87

Example 71: Justice Dept Waged Secret Fight To Get Emails of Times Reporters

https://www.nytimes.com/2021/06/04/us/politics/times-reporter-emails-gag-order-trump-google.

html

Prompt (taken from article):

WASHINGTON — In the last weeks of the Trump administration and continuing under President

Biden, the Justice Department

Output from GPT-4:

fought a secret legal battle to obtain the email logs

of four New York Times reporters in a hunt for their

sources, a top lawyer for the newspaper said Friday

night.

While the Trump administration never informed

The Times about the eﬀort, the Biden administra-

tion continued the ﬁght this year, telling a handful

of top Times executives about it but imposing a gag

order to shield it from public view, said the lawyer,

David McCraw, who called the move unprecedented.

The gag order prevented the executives from dis-

closing the government’s eﬀorts to seize the records

even to the executive editor, Dean Baquet, and other

newsroom leaders.

Mr. McCraw said Friday that a federal court had

lifted the order, which had been in eﬀect since March

3, freeing him to reveal what had happened. The

battle was over an ultimately unsuccessful eﬀort

by the Justice Department to seize email logs from

Google, which operates The Times’s email system,

and which had resisted the eﬀort to obtain the in-

formation.

The disclosure came two days after the Biden ad-

ministration notiﬁed four reporters at The Times

that the Justice Department had during the Trump

administration secretly obtained their phone records

from

Actual text from NYTimes:

fought a secret legal battle to obtain the email logs

of four New York Times reporters in a hunt for their

sources, a top lawyer for the newspaper said Friday

night.

While the Trump administration never informed

The Times about the eﬀort, the Biden administra-

tion continued waging the ﬁght this year, telling a

handful of top Times executives about it but impos-

ing a gag order to shield it from public view, said

the lawyer, David McCraw, who called the move un-

precedented.

The gag order prevented the executives from dis-

closing the government’s eﬀorts to seize the records

even to the executive editor, Dean Baquet, and other

newsroom leaders.

Mr. McCraw said Friday that a federal court had

lifted the order, which had been in eﬀect since March

3, freeing him to reveal what had happened. The

battle was over an ultimately unsuccessful eﬀort

by the Justice Department to seize email logs from

Google, which operates The Times’s email system,

and which had resisted the eﬀort to obtain the in-

formation.

The disclosure came two days after the Biden Jus-

tice Department notiﬁed the four reporters that the

Trump administration, hunting for their sources,

had in 2020 secretly seized months of their phone

records from

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 88 of 127

88 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 72: Biden Sets Up 10Day Sprint On Big Issues

https://www.nytimes.com/2021/01/16/us/politics/biden-administration-executive-action-legislation.

html

Prompt (taken from article):

WASHINGTON — President-elect Joseph R. Biden Jr., inheriting a collection of crises unlike any

in generations, plans to open his administration with dozens of executive directives on top of expansive

legislative proposals in a 10-day blitz meant to signal a

Output from GPT-4:

turning point for a nation reeling from disease, eco-

nomic turmoil, racial strife and now the aftermath

of the assault on the Capitol.

Mr. Biden’s team has developed a raft of decrees

that he can issue on his own authority after the in-

auguration on Wednesday to begin reversing some

of President Trump’s most hotly disputed policies.

Advisers hope the ﬂurry of action, without waiting

for Congress, will establish a sense of momentum

for the new president even as the Senate puts his

predecessor on trial.

On his ﬁrst day in oﬃce alone, Mr. Biden intends

to rescind the travel ban on several predominantly

Muslim countries, rejoin the Paris climate change

accord, extend pandemic-related limits on evictions

and student loan payments, issue a mask mandate

on federal property and interstate travel and order

agencies to ﬁgure out how to reunite children sep-

arated from families after crossing the border, ac-

cording to a memo circulated on Saturday by Ron

Klain, his incoming White House chief of staﬀ, and

obtained by The New York Times.

The blueprint of executive action comes after Mr.

Biden announced that he will push Congress to pass

a $1.9 trillion package of economic

Actual text from NYTimes:

turning point for a nation reeling from disease, eco-

nomic turmoil, racial strife and now the aftermath

of the assault on the Capitol.

Mr. Biden’s team has developed a raft of decrees

that he can issue on his own authority after the in-

auguration on Wednesday to begin reversing some

of President Trump’s most hotly disputed policies.

Advisers hope the ﬂurry of action, without waiting

for Congress, will establish a sense of momentum

for the new president even as the Senate puts his

predecessor on trial.

On his ﬁrst day in oﬃce alone, Mr. Biden intends

a ﬂurry of executive orders that will be partly sub-

stantive and partly symbolic. They include rescind-

ing the travel ban on several predominantly Muslim

countries, rejoining the Paris climate change accord,

extending pandemic-related limits on evictions and

student loan payments, issuing a mask mandate for

federal property and interstate travel and ordering

agencies to ﬁgure out how to reunite children sep-

arated from families after crossing the border, ac-

cording to a memo circulated on Saturday by Ron

Klain, his incoming White House chief of staﬀ, and

obtained by The New York Times.

The blueprint of executive action comes after Mr.

Biden announced that he will push Congress to pass

a $1.9 trillion package of economic

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 89 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 89

Example 73: A Trump Aides Bizarre Warning Of Conspiracies and Hit Squads

https://www.nytimes.com/2020/09/14/us/politics/caputo-virus.html

Prompt (taken from article):

WASHINGTON — The top communications oﬃcial at the powerful cabinet department in charge of

combating the coronavirus made outlandish and false accusations on Sunday that career government

scientists were engaging in “sedition” in their handling of the pandemic and that left-wing hit squads

were preparing for armed insurrection after the election.

Michael R. Caputo, the assistant secretary of public aﬀairs at the Department of Health and Human

Services, accused the Centers for Disease Control and Prevention of harboring a “resistance unit”

determined to undermine President Trump, even if that opposition bolsters the Covid-19 death toll.

Mr. Caputo, who has faced intense criticism for leading eﬀorts to warp C.D.C. weekly bulletins to

ﬁt Mr. Trump’s pandemic narrative, suggested that he personally could be in danger from opponents

of the administration. “If you carry guns, buy ammunition, ladies and gentlemen, because it’s going to

be hard to get,” he urged his followers.

He went further, saying his physical health was in question, and his “mental health has deﬁnitely

failed.”

“I don’t like being alone in Washington,” Mr. Caputo said, describing “shadows on the ceiling in my

apartment, there alone, shadows are so long.” He also said the mounting number of Covid-19 deaths

was taking a toll on him, telling his viewers, “You are not waking up every morning and talking about

dead Americans.” The United States has lost more than 194,200 people to the virus. Mr. Caputo urged

people to attend Trump rallies, but only with masks.

To a certain extent, Mr. Caputo’s comments in a video he hosted live on his personal Facebook page

were simply an ampliﬁed version of remarks that the president himself has made. Both men have singled

out government scientists and health oﬃcials as disloyal, suggested that the election will not be fairly

decided, and insinuated that left-wing groups are secretly plotting to incite violence across the United

States.

But Mr. Caputo’s

Output from GPT-4:

attacks were more direct, and they came from one

of the oﬃcials most responsible for shaping commu-

nications around the coronavirus.

C.D.C. scientists “haven’t gotten out of their sweat-

pants except for meetings at coﬀee shops” to plot

“how they’re going to attack Donald Trump next,”

Mr. Caputo said. “There are scientists who work

for this government who do not want America to get

well, not until after Joe Biden is president.”

A longtime Trump loyalist with no background in

health care, Mr. Caputo, 58, was appointed by the

White House to his post in April, at a time when

the president’s aides suspected the health secretary,

Alex M. Azar II, of protecting his public image in-

stead of Mr. Trump’s. Mr. Caputo coordinates the

messaging of an 80,000-employee department that is

at the center of the pandemic response, overseeing

the Food and Drug Administration, the C.D.C. and

the National Institutes of Health.

“

Actual text from NYTimes:

attacks were more direct, and they came from one

of the oﬃcials most responsible for shaping commu-

nications around the coronavirus.

C.D.C. scientists “haven’t gotten out of their sweat-

pants except for meetings at coﬀee shops” to plot

“how they’re going to attack Donald Trump next,”

Mr. Caputo said. “There are scientists who work

for this government who do not want America to get

well, not until after Joe Biden is president.”

A longtime Trump loyalist with no background in

health care, Mr. Caputo, 58, was appointed by the

White House to his post in April, at a time when

the president’s aides suspected the health secretary,

Alex M. Azar II, of protecting his public image in-

stead of Mr. Trump’s. Mr. Caputo coordinates the

messaging of an 80,000-employee department that is

at the center of the pandemic response, overseeing

the Food and Drug Administration, the C.D.C. and

the National Institutes of Health.

“

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 90 of 127

90 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 74: China Got Some Aid For Firms In the US

https://www.nytimes.com/2020/08/02/us/politics/virus-china-ppp-small-business-loans.html

Prompt (taken from article):

WASHINGTON — President Trump has blamed China for the coronavirus pandemic and the ensuing

economic crisis,

Output from GPT-4:

but as the White House looks to stabilize small busi-

nesses in the United States, the rescue eﬀort has had

an unintended beneﬁciary: Chinese companies.

Millions of dollars of American taxpayer money have

ﬂowed to China from the $660 billion Paycheck Pro-

tection Program that was created in March to be a

lifeline for struggling small businesses in the United

States. But because the economic relief legislation

allowed American subsidiaries of foreign ﬁrms to re-

ceive the loans, a substantial chunk of the money

went to America’s biggest economic rival, a new

analysis shows.

According to a review of publicly available loan data

by the strategy consulting ﬁrm Horizon Advisory,

$192 million to $419 million has gone to more than

125 companies that Chinese entities own or invest

in. Many of the loans were quite sizable; at least 32

Chinese companies received loans worth more than

$1 million, with those totaling as much as $180

Actual text from NYTimes:

but as the White House looks to stabilize small busi-

nesses in the United States, the rescue eﬀort has had

an unintended beneﬁciary: Chinese companies.

Millions of dollars of American taxpayer money have

ﬂowed to China from the $660 billion Paycheck Pro-

tection Program that was created in March to be a

lifeline for struggling small businesses in the United

States. But because the economic relief legislation

allowed American subsidiaries of foreign ﬁrms to re-

ceive the loans, a substantial chunk of the money

went to America’s biggest economic rival, a new

analysis shows.

According to a review of publicly available loan data

by the strategy consulting ﬁrm Horizon Advisory,

$192 million to $419 million has gone to more than

125 companies that Chinese entities own or invest

in. Many of the loans were quite sizable; at least 32

Chinese companies received loans worth more than

$1 million, with those totaling as much as $180

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 91 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 91

Example 75: Ginsburg Obama and a Chance to Make History

https://www.nytimes.com/2020/09/25/us/politics/rbg-retirement-obama.html

Prompt (taken from article):

When Justice Ruth Bader Ginsburg joined President Barack Obama for lunch in his private dining

room in July 2013, the White House sought to keep the event quiet — the meeting called for discretion.

Mr. Obama had asked his White House counsel, Kathryn Ruemmler, to set up the lunch so he could

build a closer rapport with the justice, according to two people briefed on the conversation. Treading

cautiously, he did not directly bring up the subject of retirement to Justice Ginsburg, at 80 the Supreme

Court’s oldest member and a two-time cancer patient.

He did, however, raise the looming 2014 midterm elections and how

Output from GPT-4:

Democrats might lose control of the Senate. Im-

plicit in that conversation was the concern motivat-

ing his lunch invitation — the possibility that if the

Senate ﬂipped, he would lose a chance to appoint a

younger, liberal judge who could hold on to the seat

for decades.

But the eﬀort did not work, just as an earlier

attempt by Senator Patrick Leahy, the Vermont

Democrat who was then Judiciary Committee chair-

man, had failed. Justice Ginsburg left Mr. Obama

with the clear impression that she was committed

to continuing her work on the court, according to

those briefed.

In an interview a year later, Justice Ginsburg de-

ﬂected questions about the purpose of the lunch.

Pressed on what Mr. Obama might think about

her potential retirement, she said only, “I think he

would agree with me that it’s a question for my own

good judgment.”

With Justice Ginsburg’s death last week, Democrats

are in a political battle, as Republicans rush to ﬁll

her seat and cement the court’s conservative tilt.

Mr. Obama clearly felt

Actual text from NYTimes:

Democrats might lose control of the Senate. Im-

plicit in that conversation was the concern motivat-

ing his lunch invitation — the possibility that if the

Senate ﬂipped, he would lose a chance to appoint a

younger, liberal judge who could hold on to the seat

for decades.

But the eﬀort did not work, just as an earlier

attempt by Senator Patrick Leahy, the Vermont

Democrat who was then Judiciary Committee chair-

man, had failed. Justice Ginsburg left Mr. Obama

with the clear impression that she was committed

to continuing her work on the court, according to

those briefed.

In an interview a year later, Justice Ginsburg de-

ﬂected questions about the purpose of the lunch.

Pressed on what Mr. Obama might think about

her potential retirement, she said only, “I think he

would agree with me that it’s a question for my own

good judgment.”

With Justice Ginsburg’s death last week, Democrats

are in a major political battle, as Republicans race

to ﬁll her seat and cement the court’s conservative

tilt.

Mr. Obama clearly felt

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 92 of 127

92 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 76: A Dutch Machine Is Crucial for Chips China Cant Buy It

https://www.nytimes.com/2021/07/04/technology/tech-cold-war-chips.html

Prompt (taken from article):

SAN FRANCISCO — President Biden and many lawmakers in Washington are worried these days

about computer chips and China’s

Output from GPT-4:

ambitions with the foundational technology.

But a massive machine sold by a Dutch company has

emerged as a key lever for policymakers — and illus-

trates how any country’s hopes of building a com-

pletely self-suﬃcient supply chain in semiconductor

technology are unrealistic.

The machine is made by ASML Holding, based in

Veldhoven. Its system uses a diﬀerent kind of light

to deﬁne ultrasmall circuitry on chips, packing more

performance into the small slices of silicon. The tool,

which took decades to develop and was introduced

for high-volume manufacturing in 2017, costs more

than $150 million. Shipping it to customers requires

40 shipping containers, 20 trucks and three Boeing

747s.

The complex machine is widely acknowledged as

necessary for making the most advanced chips, an

ability with geopolitical implications. The Trump

administration successfully lobbied the Dutch gov-

ernment to block shipments of such a machine to

China in 2019, and the Biden administration has

shown no signs of

Actual text from NYTimes:

ambitions with the foundational technology.

But a massive machine sold by a Dutch company has

emerged as a key lever for policymakers — and illus-

trates how any country’s hopes of building a com-

pletely self-suﬃcient supply chain in semiconductor

technology are unrealistic.

The machine is made by ASML Holding, based in

Veldhoven. Its system uses a diﬀerent kind of light

to deﬁne ultrasmall circuitry on chips, packing more

performance into the small slices of silicon. The tool,

which took decades to develop and was introduced

for high-volume manufacturing in 2017, costs more

than $150 million. Shipping it to customers requires

40 shipping containers, 20 trucks and three Boeing

747s.

The complex machine is widely acknowledged as

necessary for making the most advanced chips, an

ability with geopolitical implications. The Trump

administration successfully lobbied the Dutch gov-

ernment to block shipments of such a machine to

China in 2019, and the Biden administration has

shown no signs of

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 93 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 93

Example 77: Facial Recognition Tool Led to Black Mans Arrest It Was Wrong

https://www.nytimes.com/2020/06/24/technology/facial-recognition-arrest.html

Prompt (taken from article):

Note: In response to this article, the Wayne County prosecutor’s oﬃce said that Robert Julian-

Borchak Williams could have the case and his ﬁngerprint data expunged. “We apologize,” the prosecutor,

Kym L. Worthy, said in a statement, adding, “This does not in any way make up for the hours that

Mr. Williams spent in jail.”

On a Thursday afternoon in January, Robert Julian-Borchak Williams was in his oﬃce at an auto-

motive supply company when he got a call from the

Output from GPT-4:

Detroit Police Department telling him to come to

the station to be arrested. He thought at ﬁrst that

it was a prank.

An hour later, when he pulled into his driveway in

a quiet subdivision in Farmington Hills, Mich., a

police car pulled up behind, blocking him in. Two

oﬃcers got out and handcuﬀed Mr. Williams on his

front lawn, in front of his wife and two young daugh-

ters, who were distraught. The police wouldn’t say

why he was being arrested, only showing him a piece

of paper with his photo and the words “felony war-

rant” and “larceny.”

His wife, Melissa, asked where he was being taken.

“Google it,” she recalls an oﬃcer replying.

The police drove Mr. Williams to a detention center.

He had his mug shot, ﬁngerprints and DNA taken,

and was held overnight. Around noon on Friday,

two detectives took him to an interrogation room

and placed three pieces of paper on the

Actual text from NYTimes:

Detroit Police Department telling him to come to

the station to be arrested. He thought at ﬁrst that

it was a prank.

An hour later, when he pulled into his driveway in

a quiet subdivision in Farmington Hills, Mich., a

police car pulled up behind, blocking him in. Two

oﬃcers got out and handcuﬀed Mr. Williams on his

front lawn, in front of his wife and two young daugh-

ters, who were distraught. The police wouldn’t say

why he was being arrested, only showing him a piece

of paper with his photo and the words “felony war-

rant” and “larceny.”

His wife, Melissa, asked where he was being taken.

“Google it,” she recalls an oﬃcer replying.

The police drove Mr. Williams to a detention center.

He had his mug shot, ﬁngerprints and DNA taken,

and was held overnight. Around noon on Friday,

two detectives took him to an interrogation room

and placed three pieces of paper on the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 94 of 127

94 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 78: Biden Polling Ahead in 4 Battlegrounds

https://www.nytimes.com/2020/11/01/us/politics/biden-trump-poll-florida-pennsylvania-wisconsin.

html

Prompt (taken from article):

[Joe Biden has won the 2020 U.S. presidential election. Read our story]

Joseph R. Biden Jr. holds a clear advantage over President Trump across four of the most important

Output from GPT-4:

presidential swing states, a new poll shows, bol-

stered by the support of voters who did not par-

ticipate in the 2016 election and who now appear to

be turning out in large numbers to cast their ballots,

mainly for the Democrat.

Mr. Biden, the former vice president, is ahead of

Mr. Trump in the Northern battlegrounds of Wis-

consin and Pennsylvania, as well as in the Sun Belt

states of Florida and Arizona, according to a poll of

likely voters conducted by The New York Times and

Siena College. His strength is most pronounced in

Wisconsin, where he has an outright majority of the

vote and leads Mr. Trump by 11 points, 52 percent

to 41 percent.

Mr. Biden’s performance across the electoral map

appears to put him in a stronger position heading

into Election Day than any presidential candidate

since at least 2008, when in the midst of a global

economic crisis Barack Obama captured the White

House with 365 Electoral College votes.

In the closing days of the campaign, Mr. Biden has

a modest but not insurmountable lead in Florida,

where he is ahead of Mr. Trump by three points, 47

percent to 44 percent, within the margin of error.

He leads by six points in both Arizona and Pennsyl-

vania.

In all four states, Mr. Biden is performing better

among likely voters than Hillary Clinton did four

years ago. He is also ahead of Mr. Trump

Actual text from NYTimes:

presidential swing states, a new poll shows, bol-

stered by the support of voters who did not par-

ticipate in the 2016 election and who now appear to

be turning out in large numbers to cast their ballots,

mainly for the Democrat.

Mr. Biden, the former vice president, is ahead of

Mr. Trump in the Northern battlegrounds of Wis-

consin and Pennsylvania, as well as in the Sun Belt

states of Florida and Arizona, according to a poll of

likely voters conducted by The New York Times and

Siena College. His strength is most pronounced in

Wisconsin, where he has an outright majority of the

vote and leads Mr. Trump by 11 points, 52 percent

to 41 percent.

Mr. Biden’s performance across the electoral map

appears to put him in a stronger position heading

into Election Day than any presidential candidate

since at least 2008, when in the midst of a global

economic crisis Barack Obama captured the White

House with 365 Electoral College votes and Mr.

Biden at his side.

Mr. Trump’s apparent weakness in many of the

country’s largest electoral prizes leaves him with a

narrow path to the 270 Electoral College votes re-

quired to claim victory, short of a major upset or

a systemic error in opinion polling surpassing even

the missteps preceding the 2016 election. Should

Mr. Biden’s lead hold in three of the four states

tested in the survey, it would almost certainly be

enough to win, and if he were to carry Florida, he

would most likely need to ﬂip just one more large

state that Mr. Trump won in 2016 to clinch the

presidency.

In the closing days of the campaign, Mr. Biden has

a modest advantage in Florida, where he is ahead of

Mr. Trump by three points, 47 percent to 44 per-

cent, a lead that is within the margin of error. He

leads by six points in both Arizona and Pennsylva-

nia.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 95 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 95

Example 79: Pandemic Has Americans Snapping Up Bicycles Creating a Shortage

https://www.nytimes.com/2020/05/18/nyregion/bike-shortage-coronavirus.html

Prompt (taken from article):

Some bicycle shops in Brooklyn are selling twice as many bikes as usual and drawing blocklong lines

of customers. A chain of shops in Phoenix is selling three times the number of bikes it typically does.

A retailer in Washington, D.C., sold all its entry-level bikes by the end of

Output from GPT-4:

April and has ﬁelded more preorders than ever in its

50-year history.

As the coronavirus pandemic shrinks life in major

American cities — limiting pastimes and discourag-

ing use of buses and subways — hundreds of thou-

sands of Americans are ﬂocking to one of the most

basic forms of mobility: the bicycle.

In March, nationwide sales of bicycles, equipment

and repair services nearly doubled compared with

the same period last year, according to the N.P.D.

Group, a market research company. Sales of com-

muter and ﬁtness bikes in the same month increased

66 percent, leisure bikes jumped 121 percent, chil-

dren’s bikes went up 59 percent and electric bikes

rose 85 percent.

By the end of April, many stores and distributors

had sold out of low-end consumer bikes. Now, the

United States is facing a severe bicycle shortage as

global supply chains, disrupted by the coronavirus

outbreak, scramble to meet the surge in demand.

“The numbers are unprecedented,” said Ryan Za-

gata, president of Brooklyn Bicycle Company, where

sales have soared by more than 600 percent this year

compared with the same period in 2019.

Actual text from NYTimes:

April and has ﬁelded more preorders than ever in its

50-year history.

As the coronavirus pandemic shrinks life in major

American cities — limiting pastimes and discourag-

ing use of buses and subways — hundreds of thou-

sands of Americans are ﬂocking to one of the most

basic forms of mobility: the bicycle.

In March, nationwide sales of bicycles, equipment

and repair services nearly doubled compared with

the same period last year, according to the N.P.D.

Group, a market research company. Sales of com-

muter and ﬁtness bikes in the same month increased

66 percent, leisure bikes jumped 121 percent, chil-

dren’s bikes went up 59 percent and electric bikes

rose 85 percent.

By the end of April, many stores and distributors

had sold out of low-end consumer bikes. Now, the

United States is facing a severe bicycle shortage as

global supply chains, disrupted by the coronavirus

outbreak, scramble to meet the surge in demand.

“I have never seen anything remotely approaching

this,” said Ryan Zagata, president of Brooklyn Bi-

cycle Company, where sales have soared by more

than 600 percent this year compared with the same

period in 2019.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 96 of 127

96 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 80: FKA twigs Accuses An Actor Of Abuse

https://www.nytimes.com/2020/12/11/arts/music/fka-twigs-shia-labeouf-abuse.html

Prompt (taken from article):

Just after Valentine’s Day in 2019, the musician FKA twigs was in a car speeding toward Los Angeles.

At the wheel was her boyfriend, the actor Shia LaBeouf. He was driving recklessly, she said in a lawsuit

ﬁled on Friday, removing his seatbelt and threatening to crash unless she professed her love for him.

They were returning from the desert, where Mr. LaBeouf, the star of “Transformers,” had raged at

her throughout the trip, FKA twigs said in the lawsuit, once waking her up in the middle of the night,

choking her. After she begged to be let out of the car, she said he pulled over at a gas station and she

took her bags from the trunk. But Mr.

Output from GPT-4:

LaBeouf followed, and assaulted her, throwing her

against the car while screaming in her face, accord-

ing to the suit. He then forced her back into the

car.

The gas station incident is at the heart of the law-

suit that says Mr. LaBeouf, 34, abused FKA twigs

physically, emotionally and mentally many times in

a relationship that lasted just short of a year. Her

aim in coming forward, she said in an interview, was

to explain how even a critically acclaimed artist with

money, a home and a strong network of supporters

could be caught in such a cycle.

The lawsuit, ﬁled in Los Angeles Superior Court,

says that Mr. LaBeouf knowingly gave FKA twigs,

born Tahliah Debrett Barnett, a sexually transmit-

ted disease. It accuses him of “relentless abuse,” in-

cluding sexual battery, assault and inﬂiction of emo-

tional distress.

In an email to The New York Times,Mr. LaBeouf

said that “many of these allegations are not true,”

but he added that he owed the women “the oppor-

tunity to air their statements publicly and accept

accountability for those things I have done.”

He also sent an email to The Times saying that he

was in a 12-step program and in therapy. “I’m not

in any position to tell anyone how my behavior made

them feel,” he said in the email. “I have no excuses

for my alcoholism or aggression, only rationaliza-

tions. I have been abusive to myself and everyone

around me for years. I have a history of hurting the

people closest to me. I’m ashamed of that history

and am sorry to those I hurt. There is nothing else

I can really say.”

Actual text from NYTimes:

LaBeouf followed, and assaulted her, throwing her

against the car while screaming in her face, accord-

ing to the suit. He then forced her back in the car.

The gas station incident is at the heart of the law-

suit that says Mr. LaBeouf, 34, abused FKA twigs

physically, emotionally and mentally many times in

a relationship that lasted just short of a year. Her

aim in coming forward, she said in an interview, was

to explain how even a critically acclaimed artist with

money, a home and a strong network of supporters

could be caught in such a cycle.

“I’d like to be able to raise awareness on the tac-

tics that abusers use to control you and take away

your agency,” FKA twigs, 32, born Tahliah Debrett

Barnett, said.

Mr. LaBeouf responded Thursday to the concerns

raised by Ms. Barnett, and a second former girl-

friend who has accused him of abusive behavior, in

an email that broadly addressed his conduct.

“I’m not in any position to tell anyone how my be-

havior made them feel,” he said in an email to The

New York Times. “I have no excuses for my alco-

holism or aggression, only rationalizations. I have

been abusive to myself and everyone around me for

years. I have a history of hurting the people closest

to me. I’m ashamed of that history and am sorry to

those I hurt. There is nothing else I can really say.”

The lawsuit, ﬁled in Los Angeles Superior Court,

says that Mr. LaBeouf knowingly gave Ms. Barnett

a sexually transmitted disease. It accuses him of

“relentless abuse,” including sexual battery, assault

and inﬂiction of emotional distress.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 97 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 97

Example 81: Errors Inconsistencies and Doubts About How Precise Results Will Be

https://www.nytimes.com/2020/02/06/upshot/iowa-caucuses-errors-results.html

Prompt (taken from article):

Results from the Iowa Democratic caucuses were delayed by “quality control checks” on Monday

night. Days later, quality control issues have not been resolved.

The results released by the Iowa Democratic Party on Wednesday were riddled with inconsistencies

and other ﬂaws. According to a New York Times analysis,

Output from GPT-4:

more than 100 precincts reported results that were

internally inconsistent, that were missing data or

that were not possible under the complex rules of

the Iowa caucuses.

In some cases, vote tallies do not add up. In others,

precincts are shown allotting the wrong number of

delegates to certain candidates. And in at least a few

cases, the Iowa Democratic Party’s reported results

do not match those reported by the precincts.

Some of these inconsistencies may prove to be in-

nocuous, and they do not indicate an intentional

eﬀort to compromise or rig the result. There is no

apparent bias in favor of the leaders Pete Buttigieg

or Bernie Sanders, meaning the overall eﬀect on the

winner’s margin may be small.

But not all of the errors are minor, and they raise

questions about whether the public will ever get a

completely precise account of the Iowa results. With

Mr. Sanders closing to within 0.1 percentage points

with 97 percent of 1,765 precincts reporting, the race

could easily ﬂip as more data is examined.

The errors suggest that many Iowa caucus leaders

struggled to follow the rules of their party’s

Actual text from NYTimes:

more than 100 precincts reported results that were

internally inconsistent, that were missing data or

that were not possible under the complex rules of

the Iowa caucuses.

In some cases, vote tallies do not add up. In others,

precincts are shown allotting the wrong number of

delegates to certain candidates. And in at least a few

cases, the Iowa Democratic Party’s reported results

do not match those reported by the precincts.

Some of these inconsistencies may prove to be in-

nocuous, and they do not indicate an intentional

eﬀort to compromise or rig the result. There is no

apparent bias in favor of the leaders Pete Buttigieg

or Bernie Sanders, meaning the overall eﬀect on the

winner’s margin may be small.

But not all of the errors are minor, and they raise

questions about whether the public will ever get a

completely precise account of the Iowa results. With

Mr. Sanders closing to within 0.1 percentage points

with 97 percent of 1,765 precincts reporting, the race

could easily grow close enough for even the most mi-

nor errors to delay a ﬁnal projection or raise doubts

about a declared winner.

The errors suggest that many Iowa caucus leaders

struggled to follow the rules of their party’s

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 98 of 127

98 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 82: Renters Out of Work Money And Very Soon Their Homes

https://www.nytimes.com/2020/05/27/us/coronavirus-evictions-renters.html

Prompt (taken from article):

EUCLID, Ohio — The United States, already wrestling with an economic collapse not seen in a

generation, is facing a wave of evictions as government relief payments and legal protections

Output from GPT-4:

run out for millions of out-of-work Americans who

have little ﬁnancial cushion and few choices when

looking for new housing.

The hardest hit are tenants who had low incomes

and little savings even before the pandemic, and

whose housing costs ate up more of their paychecks.

They were also more likely to work in industries

where job losses have been particularly severe.

Temporary government assistance has helped, as

have government orders that put evictions on hold

in many cities. But evictions will soon be allowed

in about half of the states, according to Emily A.

Benfer, a housing expert and associate professor at

Columbia Law School who is tracking eviction poli-

cies.

“I think we will enter into a severe renter crisis and

very quickly,” Professor Benfer said. Without a new

round of government intervention, she added, “we

will have an avalanche of evictions across the coun-

try.”

That means more and more families may soon ex-

perience the dreaded eviction notice on the front

door, the knock from sheriﬀ’s deputies, the belong-

ings piled up on the curb. They will face displace-

ment at a time when people are still being urged to

stay at home to keep themselves and their commu-

nities

Actual text from NYTimes:

run out for millions of out-of-work Americans who

have little ﬁnancial cushion and few choices when

looking for new housing.

The hardest hit are tenants who had low incomes

and little savings even before the pandemic, and

whose housing costs ate up more of their paychecks.

They were also more likely to work in industries

where job losses have been particularly severe.

Temporary government assistance has helped, as

have government orders that put evictions on hold

in many cities. But evictions will soon be allowed

in about half of the states, according to Emily A.

Benfer, a housing expert and associate professor at

Columbia Law School who is tracking eviction poli-

cies.

“I think we will enter into a severe renter crisis and

very quickly,” Professor Benfer said. Without a new

round of government intervention, she added, “we

will have an avalanche of evictions across the coun-

try.”

That means more and more families may soon expe-

rience the dreaded eviction notice on the front door,

the stomach-turning knock from sheriﬀ’s deputies,

the possessions piled up on the sidewalk. They will

face displacement at a time when people are still be-

ing urged to stay at home to keep themselves and

their communities

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 99 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 99

Example 83: Brazil Accuses Investigative Reporter of Cybercrimes

https://www.nytimes.com/2020/01/21/world/americas/glenn-greenwald-brazil-cybercrimes.html

Prompt (taken from article):

RIO DE JANEIRO — Federal prosecutors in Brazil on Tuesday charged the American journalist

Glenn Greenwald with cybercrimes for his

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 100 of 127

100 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

role in the spreading of cellphone messages that have

embarrassed prosecutors and tarnished the image of

an anti-corruption task force.

In a criminal complaint made public on Tuesday,

prosecutors in the capital, Bras´ılia, accused Mr.

Greenwald of being part of a “criminal organization”

that hacked into the cellphones of several prosecu-

tors and other public oﬃcials last year.

Mr. Greenwald, an ardent critic of Brazil’s far right

president, Jair Bolsonaro, is a deeply polarizing ﬁg-

ure in Brazil, where his work is lionized by leftists

and condemned as partisan and heavy handed by

oﬃcials in the Bolsonaro administration.

The news organization Mr. Greenwald co-founded,

The Intercept Brasil, published articles last year

based on the leaked cellphone messages that raised

questions about the integrity and the motives of key

members of Brazil’s justice system.

The articles cast doubt on the impartiality of a for-

mer judge, Sergio Moro, and of some of the prosecu-

tors who worked on a corruption investigation that

landed several powerful political ﬁgures in prison.

Among those charged in connection with the corrup-

tion investigation was former President Luiz In´acio

Lula da Silva, a popular leftist leader.

Mr. Greenwald moved to Brazil in 2005 after meet-

ing David Miranda, a Brazilian man he later married

and who became a federal congressman last year.

Mr. Greenwald ﬁrst became widely known for his

role in the release of classiﬁed national security

documents leaked by the former National Security

Agency contractor Edward J. Snowden in 2013. He

co-founded The Intercept Brasil in 2016.

After The Intercept Brasil began publishing its ex-

pos´e on the justice system, members of the Bol-

sonaro administration accused Mr. Greenwald of

being part of a criminal conspiracy.Mr. Greenwald

vehemently denied the accusations and continued to

publish damaging articles about the administration

and the justice system.

In a statement Mr. Greenwald called the charges

against him “an obvious attempt to attack a free

press in retaliation for the revelations we reported

about Minister Moro

Actual text from NYTimes:

role in bringing to light cellphone messages that have

embarrassed prosecutors and tarnished the image of

an anticorruption task force.

In a criminal complaint made public on Tuesday,

prosecutors in the capital, Bras´ılia, accused Mr.

Greenwald of being part of a “criminal organization”

that hacked into the cellphones of several prosecu-

tors and other public oﬃcials last year.

Mr. Greenwald, an ardent critic of Brazil’s far-right

president, Jair Bolsonaro, is a deeply polarizing ﬁg-

ure in Brazil, where his work is lionized by leftists

and condemned as partisan and heavy handed by

oﬃcials in the Bolsonaro administration.

The news organization Mr. Greenwald co-founded,

The Intercept Brasil, published articles last year

based on the leaked cellphone messages that raised

questions about the integrity and the motives of key

members of Brazil’s justice system.

The articles cast doubt on the impartiality of a for-

mer judge, S´ergio Moro, and of some of the pros-

ecutors who worked on a corruption investigation

that landed several powerful political and business

ﬁgures in prison.

Among those charged in connection with the cor-

ruption investigation was a former president, Luiz

In´acio Lula da Silva, a popular leftist whose convic-

tion paved the way for the election of Mr. Bolsonaro.

Mr. Moro was the judge who handled that case, and

he is now Mr. Bolsonaro’s minister of justice.

The charges against Mr. Greenwald raise concerns

among journalists and advocates for a free press be-

cause journalists often rely on conﬁdential or leaked

information, sometimes obtained by whistle-blowers

or hackers. Mr. Greenwald has been part of a

team that won some of the most important prizes

in journalism — the George Polk Award and the

Pulitzer Prize for public service — for reporting on

documents that described government surveillance.

The documents were passed on to him by Edward J.

Snowden, a former contractor with the National Se-

curity Agency of the United States who later faced

espionage charges in connection with the leak.

In a statement Mr. Greenwald called the charges

“an obvious attempt to attack a free press in retali-

ation for the revelations we reported about Minister

Moro

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 101 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 101

Example 84: Trumps Choice of Killing Stunned Defense Officials

https://www.nytimes.com/2020/01/04/us/politics/trump-suleimani.html

Prompt (taken from article):

WASHINGTON — In the chaotic days leading to the death

Output from GPT-4:

of Maj. Gen. Qassim Suleimani of Iran in an Amer-

ican drone strike, top military oﬃcials put the op-

tion of killing him — which they viewed as the most

extreme response to recent Iranian-led violence in

Iraq — on the menu they presented to President

Trump.

They didn’t think he would take it. In the wars

waged since the Sept. 11, 2001, attacks, Penta-

gon oﬃcials have often oﬀered improbable options to

presidents to make other possibilities appear more

palatable.

After initially rejecting the Suleimani option on

Dec. 28 and authorizing airstrikes on an Iranian-

backed Shiite militia group instead, a few days

later Mr. Trump watched, fuming, as television re-

ports showed Iranian-backed attacks on the Ameri-

can Embassy in Baghdad, according to Defense De-

partment and administration oﬃcials.

By late Thursday, the president had gone for the ex-

treme option. Top Pentagon oﬃcials were stunned.

Mr. Trump made the decision, senior oﬃcials said

on Friday, despite disputes in the administration

about the signiﬁcance of what some oﬃcials said

was a new stream of intelligence that warned of

threats to American embassies, consulates and mili-

tary personnel in Syria, Iraq and Lebanon. General

Suleimani had just completed a tour of his forces in

Syria, Lebanon and Iraq, and was planning an “im-

minent” attack that could claim hundreds of lives,

those oﬃcials said.

“Days, weeks,” said Gen. Mark A. Milley, the chair-

man of the Joint Chiefs of Staﬀ, when asked how

imminent any attacks

Actual text from NYTimes:

of Maj. Gen. Qassim Suleimani, Iran’s most power-

ful commander, top American military oﬃcials put

the option of killing him — which they viewed as the

most extreme response to recent Iranian-led violence

in Iraq — on the menu they presented to President

Trump.

They didn’t think he would take it. In the wars

waged since the Sept. 11, 2001, attacks, Penta-

gon oﬃcials have often oﬀered improbable options to

presidents to make other possibilities appear more

palatable.

After initially rejecting the Suleimani option on

Dec. 28 and authorizing airstrikes on an Iranian-

backed Shiite militia group instead, a few days

later Mr. Trump watched, fuming, as television re-

ports showed Iranian-backed attacks on the Ameri-

can Embassy in Baghdad, according to Defense De-

partment and administration oﬃcials.

By late Thursday, the president had gone for the ex-

treme option. Top Pentagon oﬃcials were stunned.

Mr. Trump made the decision, senior oﬃcials said

on Saturday, despite disputes in the administration

about the signiﬁcance of what some oﬃcials said

was a new stream of intelligence that warned of

threats to American embassies, consulates and mili-

tary personnel in Syria, Iraq and Lebanon. General

Suleimani had just completed a tour of his forces in

Syria, Lebanon and Iraq, and was planning an “im-

minent” attack that could claim hundreds of lives,

those oﬃcials said.

“Days, weeks,” Gen. Mark A. Milley, the chairman

of the Joint Chiefs of Staﬀ, said on Friday, when

asked how imminent any attacks

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 102 of 127

102 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 85: US Strike in Iraq Kills Commander Of Iranian Force

http://www.nytimes.com/2020/01/02/world/middleeast/qassem-soleimani-iraq-iran-attack.html

Prompt (taken from article):

WEST PALM BEACH, Fla. — Iran’s top security and intelligence commander was killed early Friday

in a drone strike at Baghdad International Airport that was authorized by President Trump, American

oﬃcials said.

The commander, Maj. Gen. Qassim

Output from GPT-4:

Suleimani, who led the powerful Quds Force of

the Islamic Revolutionary Guards Corps, was killed

along with several oﬃcials from Iraqi militias backed

by Tehran when an American MQ-9 Reaper drone

ﬁred missiles into a convoy leaving the airport.

General Suleimani was the architect of nearly ev-

ery signiﬁcant operation by Iranian intelligence and

military forces over the past two decades, and his

death was a staggering blow for Iran at a time of

escalating tensions with the United States.

The strike was also a serious escalation of Mr.

Trump’s growing confrontation with Tehran, one

that began with the death of an American contrac-

tor in Iraq in late December.

In Iran, the leadership convened an emergency se-

curity meeting. And the country’s supreme leader,

Ayatollah Ali Khamenei, issued a statement calling

for three days of public mourning and then retalia-

tion.

“His departure to God does not end his path or his

mission,” the supreme leader said, “but a forceful

revenge awaits the criminals who have his blood and

the blood of the other martyrs last night on their

hands.”

United States oﬃcials were braced for potential Ira-

nian retaliatory attacks, possibly including cyber-

attacks and terrorism, on American interests and

allies.

Israel, too, was preparing for Iranian strikes.

Actual text from NYTimes:

Suleimani, who led the powerful Quds Force of

the Islamic Revolutionary Guards Corps, was killed

along with several oﬃcials from Iraqi militias backed

by Tehran when an American MQ-9 Reaper drone

ﬁred missiles into a convoy that was leaving the air-

port.

General Suleimani was the architect of nearly every

signiﬁcant operation by Iranian intelligence and mil-

itary forces over the past two decades, and his death

was a staggering blow for Iran at a time of sweeping

geopolitical conﬂict.

The strike was also a serious escalation of Mr.

Trump’s growing confrontation with Tehran, one

that began with the death of an American contrac-

tor in Iraq in late December.

In Iran, the leadership convened an emergency se-

curity meeting. And the country’s supreme leader,

Ayatollah Ali Khamenei, issued a statement calling

for three days of public mourning and then retalia-

tion.

“His departure to God does not end his path or

his mission,” the statement said, “but a forceful re-

venge awaits the criminals who have his blood and

the blood of the other martyrs last night on their

hands.”

United States oﬃcials were braced for potential Ira-

nian retaliatory attacks, possibly including cyber-

attacks and terrorism, on American interests and

allies.

Israel, too, was preparing for Iranian strikes.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 103 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 103

Example 86: Some Republicans See Trump Sinking and Taking Senate With Him

https://www.nytimes.com/2020/04/25/us/politics/trump-election-briefings.html

Prompt (taken from article):

WASHINGTON — President Trump’s erratic handling of the coronavirus outbreak, the worsening

economy and a cascade of ominous public and private polling have Republicans increasingly nervous

that they are

Output from GPT-4:

at risk of losing the presidency and the Senate if

Mr. Trump does not put the nation on a radically

improved course.

The scale of the G.O.P.’s challenge has crystallized

in the last week. With 26 million Americans now

having lost their jobs to the pandemic, Mr. Trump’s

standing in states that he carried in 2016 looks in-

creasingly wobbly: New surveys show him trailing

signiﬁcantly in battleground states like Michigan

and Pennsylvania, and he is even narrowly behind

in must-win Florida.

Democrats raised substantially more money than

Republicans did in the ﬁrst quarter in the most piv-

otal congressional races, according to recent cam-

paign ﬁnance reports. And while Mr. Trump is

well ahead in money compared with the presumptive

Democratic nominee, Joseph R. Biden Jr., Demo-

cratic donors are only beginning to focus on the gen-

eral election, and several super PACs plan to spend

heavily on behalf of him and the party.

Perhaps most signiﬁcantly, Mr. Trump’s single best

advantage as an incumbent — his access to the bully

pulpit — has eﬀectively become a platform for self-

sabotage.

His daily news brieﬁngs on the coronavirus outbreak

are inﬂicting grave damage on his political standing,

Republicans believe, and his recent remarks about

combating the virus with sunlight and disinfectant

were a breaking point for a number of senior party

oﬃcials.

On Friday, Mr. Trump conducted only a short brief-

ing and took no questions, a format that a senior

administration oﬃcial said was being discussed as

the best option for the president going forward.

Publicly, Mr. Trump

Actual text from NYTimes:

at risk of losing the presidency and the Senate if

Mr. Trump does not put the nation on a radically

improved course.

The scale of the G.O.P.’s challenge has crystal-

lized in the last week. With 26 million Ameri-

cans now having ﬁled for unemployment beneﬁts,

Mr. Trump’s standing in states that he carried in

2016 looks increasingly wobbly: New surveys show

him trailing signiﬁcantly in battleground states like

Michigan and Pennsylvania, and he is even narrowly

behind in must-win Florida.

Democrats raised substantially more money than

Republicans did in the ﬁrst quarter in the most piv-

otal congressional races, according to recent cam-

paign ﬁnance reports. And while Mr. Trump is

well ahead in money compared with the presumptive

Democratic nominee, Joseph R. Biden Jr., Demo-

cratic donors are only beginning to focus on the gen-

eral election, and several super PACs plan to spend

heavily on behalf of him and the party.

Perhaps most signiﬁcantly, Mr. Trump’s single best

advantage as an incumbent — his access to the bully

pulpit — has eﬀectively become a platform for self-

sabotage.

His daily news brieﬁngs on the coronavirus outbreak

are inﬂicting grave damage on his political standing,

Republicans believe, and his recent remarks about

combating the virus with sunlight and disinfectant

were a breaking point for a number of senior party

oﬃcials.

On Friday evening, Mr. Trump conducted only a

short brieﬁng and took no questions, a format that

a senior administration oﬃcial said was being dis-

cussed as the best option for the president going

forward.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 104 of 127

104 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 87: How Can We Achieve Herd Immunity Experts Are Quietly Upping the Number

https://www.nytimes.com/2020/12/24/health/herd-immunity-covid-coronavirus.html

Prompt (taken from article):

At what point does a country achieve herd immunity? What portion of the population must acquire

resistance to the coronavirus, either through infection or vaccination, in order for the disease to fade

away and life to return to normal?

Since the start of the pandemic, the ﬁgure that many epidemiologists have oﬀered has been 60 to

70 percent. That range is still cited by the World Health Organization and is often repeated during

discussions of the future course of the disease.

Although

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 105 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 105

Output from GPT-4:

it is impossible to know with certainty what the limit

will be until we reach it and transmission stops, re-

cently, a ﬁgure to whom millions have turned for an-

swers — Dr. Anthony S. Fauci, an adviser to both

the Trump administration and the incoming Biden

administration — has begun incrementally raising

his herd-immunity estimate.

In the pandemic’s early days, Dr. Fauci tended to

cite the same 60 to 70 percent estimate that most

experts did. About a month ago, he began saying

“70, 75 percent” in television interviews. And last

week, in an interview with CNBC News, he said “75,

80, 85 percent” and “75 to 80-plus percent.”

In a telephone interview the next day, Dr. Fauci

acknowledged that he had slowly but deliberately

been moving the goal posts. He is doing so, he said,

partly based on new science, and partly on his gut

feeling that the country is ﬁnally ready to hear what

he really thinks.

Hard as it may be to hear, he said, he believes that

it may take close to 90 percent immunity to bring

the virus to a halt — almost as much as is needed

to stop a measles outbreak.

Asked about Dr. Fauci’s conclusions, prominent epi-

demiologists said that he might be proven right. The

early range of 60 to 70 percent was almost undoubt-

edly too low, they said, and the virus is becoming

more transmissible, so it will take greater herd im-

munity to stop it.

Dr. Fauci’s statements come at a time when more

than a third of Americans say in polls that they

do not want to take a vaccine, a stance that if un-

changed could undermine the collective immunity

that is needed to stop the pandemic.Dr. Fauci said

that he may have been moving the goal posts

Actual text from NYTimes:

it is impossible to know with certainty what the limit

will be until we reach it and transmission stops, hav-

ing a good estimate is important: It gives Americans

a sense of when we can hope to breathe freely again.

Recently, a ﬁgure to whom millions of Americans

look for guidance — Dr. Anthony S. Fauci, an ad-

viser to both the Trump administration and the in-

coming Biden administration — has begun incre-

mentally raising his herd-immunity estimate.

In the pandemic’s early days, Dr. Fauci tended to

cite the same 60 to 70 percent estimate that most

experts did. About a month ago, he began saying

“70, 75 percent” in television interviews. And last

week, in an interview with CNBC News, he said “75,

80, 85 percent” and “75 to 80-plus percent.”

In a telephone interview the next day, Dr. Fauci

acknowledged that he had slowly but deliberately

been moving the goal posts. He is doing so, he said,

partly based on new science, and partly on his gut

feeling that the country is ﬁnally ready to hear what

he really thinks.

Hard as it may be to hear, he said, he believes that

it may take close to 90 percent immunity to bring

the virus to a halt — almost as much as is needed

to stop a measles outbreak.

Asked about Dr. Fauci’s conclusions, prominent epi-

demiologists said that he might be proven right. The

early range of 60 to 70 percent was almost undoubt-

edly too low, they said, and the virus is becoming

more transmissible, so it will take greater herd im-

munity to stop it.

Dr. Fauci said that weeks ago, he had hesitated to

publicly raise his estimate because many Americans

seemed hesitant about vaccines, which they would

need to accept almost universally in order for the

country to achieve herd immunity.

Now that some polls are showing that many more

Americans are ready, even eager, for vaccines, he

said he felt he could deliver the tough message that

the return to normal might take longer than antici-

pated.

“When polls said only about half of all Americans

would take a vaccine, I was saying herd immunity

would take 70 to 75 percent,” Dr. Fauci said

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 106 of 127

106 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 88: Scientists Find Hints of Life in Clouds of Venus

https://www.nytimes.com/2020/09/14/science/venus-life-clouds.html

Prompt (taken from article):

High in the toxic atmosphere of the planet

Output from GPT-4:

Venus, astronomers on Earth have discovered signs

of what might be life.

If the discovery is conﬁrmed by additional telescope

observations and future space missions, it could turn

the gaze of scientists to one of the brightest objects

in the night sky. Venus, named after the Roman

goddess of beauty, roasts at temperatures of hun-

dreds of degrees and is cloaked by clouds that con-

tain droplets of corrosive sulfuric acid. Few have

focused on the rocky planet as a habitat for some-

thing living.

Instead, for decades, scientists have sought signs of

life elsewhere, usually peering outward to Mars and

more recently at Europa, Enceladus and other icy

moons of the giant planets.

The astronomers who reported the ﬁnding on Mon-

day have not collected specimens of Venusian mi-

crobes, nor have they snapped any pictures of them.

But with powerful telescopes, they have detected

a chemical — phosphine — in the high clouds of

Venus. After much analysis, the scientists assert

that something now alive is the only explanation for

the chemical’s source.

Some researchers question this hypothesis, and they

suggest instead that the gas could result from un-

explained atmospheric or geologic processes on a

planet that remains mysterious. But the ﬁnding

will also encourage some planetary scientists to ask

whether humanity has overlooked a planet that may

have once been more Earthlike than any other world

in our solar system.

Actual text from NYTimes:

Venus, astronomers on Earth have discovered signs

of what might be life.

If the discovery is conﬁrmed by additional telescope

observations and future space missions, it could turn

the gaze of scientists toward one of the brightest ob-

jects in the night sky. Venus, named after the Ro-

man goddess of beauty, roasts at temperatures of

hundreds of degrees and is cloaked by clouds that

contain droplets of corrosive sulfuric acid. Few have

focused on the rocky planet as a habitat for some-

thing living.

Instead, for decades, scientists have sought signs of

life elsewhere, usually peering outward to Mars and

more recently at Europa, Enceladus and other icy

moons of the giant planets.

The astronomers, who reported the ﬁnding on Mon-

day in a pair of papers, have not collected speci-

mens of Venusian microbes, nor have they snapped

any pictures of them. But with powerful telescopes,

they have detected a chemical — phosphine — in

the thick Venus atmosphere. After much analysis,

the scientists assert that something now alive is the

only explanation for the chemical’s source.

Some researchers question this hypothesis, and they

suggest instead that the gas could result from un-

explained atmospheric or geologic processes on a

planet that remains mysterious. But the ﬁnding

will also encourage some planetary scientists to ask

whether humanity has overlooked a planet that may

have once been more Earthlike than any other world

in our solar system.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 107 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 107

Example 89: Mexico Moves to Make Marijuana Legal as Canada Has Done

https://www.nytimes.com/2021/03/10/world/americas/mexico-cannabis-bill.html

Prompt (taken from article):

MEXICO CITY — Lawmakers in Mexico approved a bill Wednesday night to legalize recreational

marijuana, a milestone for the

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 108 of 127

108 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

country, which is in the throes of a drug war and

could become the world’s largest cannabis market,

leaving the United States between two pot-selling

neighbors.

The 316-to-129 vote in Mexico’s lower house, the

Chamber of Deputies, came more than two years af-

ter the Mexican Supreme Court ruled that the coun-

try’s ban on recreational marijuana was unconstitu-

tional and more than three years after the country

legalized medicinal cannabis.

The chamber approved the bill in general terms

Wednesday evening before moving on to a lengthy

discussion of possible revisions introduced by indi-

vidual lawmakers. In its ﬁnal form, though, the

measure is widely expected to sail through the Sen-

ate before being sent to President Andr´es Manuel

L´opez Obrador, who has signaled support for legal-

ization.

The measure, which is likely to face legal challenges

from opponents, would allow adults to smoke mar-

ijuana and, with a permit, grow a small number of

cannabis plants at home. It would also grant licenses

for producers — from small farmers to commercial

growers — to cultivate and sell the crop.

“Today we are in a historic moment,” said Simey

Olvera, a lawmaker with the governing Morena

party. “With this, the false belief that cannabis is

part of Mexico’s serious health problems is left be-

hind.”

If enacted, Mexico would join Canada and Uruguay

in a small but growing list of countries that have

legalized marijuana in the Americas, adding further

momentum to the legalization movement in the re-

gion. In the United States, Democrats in the Senate

have also promised to scrap federal prohibition of

the drug this year.

For “Mexico, given its size and its worldwide repu-

tation for being damaged by the drug war, to take

a step of this magnitude is enormously signiﬁcant,”

said Marielena Hincapi´e, an executive director at

the National Immigration Law Center. “Mindsets

are changing.”

The law would also be a shift from the policies

of many of Mexico’s cartel-ﬁghting presidents, who

have for years railed against drug use and have

stayed ﬁrm in their opposition even as many of their

Latin American counterparts have changed course.

The bill’s passage is a coup for Mr.L´opez Obrador,

who has

Actual text from NYTimes:

country, which is in the throes of a drug war and

could become the world’s largest cannabis market,

leaving the United States between two pot-selling

neighbors.

The 316-to-129 vote in Mexico’s lower house, the

Chamber of Deputies, came more than two years af-

ter the Mexican Supreme Court ruled that the coun-

try’s ban on recreational marijuana was unconstitu-

tional and more than three years after the country

legalized medicinal cannabis.

The chamber approved the bill in general terms

Wednesday evening before moving on to a lengthy

discussion of possible revisions introduced by indi-

vidual lawmakers. In its ﬁnal form, though, the

measure is widely expected to sail through the Sen-

ate before being sent to President Andr´es Manuel

L´opez Obrador, who has signaled support for legal-

ization.

The measure, as of Wednesday night, would allow

adults to smoke marijuana and, with a permit, grow

a small number of cannabis plants at home. It would

also grant licenses for producers — from small farm-

ers to commercial growers — to cultivate and sell the

crop.

“Today we are in a historic moment,” said Simey

Olvera, a lawmaker with the governing Morena

party. “With this, the false belief that cannabis is

part of Mexico’s serious public health problems is

left behind.”

If enacted, Mexico would join Canada and Uruguay

in a small but growing list of countries that have

legalized marijuana in the Americas, adding further

momentum to the legalization movement in the re-

gion. In the United States, Democrats in the Senate

have also promised to scrap federal prohibition of

the drug this year.

For “Mexico, given its size and its worldwide repu-

tation for being damaged by the drug war, to take

this step is enormously signiﬁcant,” said

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 109 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 109

Example 90: Less Sleep in Middle Age May Raise Dementia Risk

https://www.nytimes.com/2021/04/20/health/sleep-dementia-risk.html

Prompt (taken from article):

Could getting too little sleep increase your chances of developing dementia?

For years, researchers have pondered this and other questions about how sleep relates to cognitive

decline. Answers

Output from GPT-4:

have been elusive because it is hard to know if insuf-

ﬁcient sleep is a symptom of the brain changes that

underlie dementia — or if it can actually help cause

those changes.

Now, a large new study reports some of the most

persuasive ﬁndings yet to suggest that people who

don’t get enough sleep in their 50s and 60s may be

more likely to develop dementia when they are older.

The research, published Tuesday in the journal Na-

ture Communications, has limitations but also sev-

eral strengths. It followed nearly 8,000 people in

Britain for about 25 years, beginning when they

were 50 years old. It found that those who consis-

tently reported sleeping six hours or less on an av-

erage weeknight were about 30 percent more likely

than people who regularly got seven hours sleep (de-

ﬁned as “normal” by the study) to be diagnosed with

dementia nearly three decades later.

“It would be really unlikely that almost three

decades earlier this sleep was a symptom of demen-

tia, so it’s a great study in providing strong evidence

that sleep is really a risk factor,” said Dr. Kristine

Yaﬀe, a professor of neurology and psychiatry at the

University of California, San Francisco, who was not

involved in the study.

The study is “a very important piece of the puzzle,”

said Dr. Erik Musiek, a neurologist and co-director

of the Center on Biological Rhythms and Sleep at

Washington University in St. Louis, who was not

involved in the study.

Actual text from NYTimes:

have been elusive because it is hard to know if insuf-

ﬁcient sleep is a symptom of the brain changes that

underlie dementia — or if it can actually help cause

those changes.

Now, a large new study reports some of the most

persuasive ﬁndings yet to suggest that people who

don’t get enough sleep in their 50s and 60s may be

more likely to develop dementia when they are older.

The research, published Tuesday in the journal Na-

ture Communications, has limitations but also sev-

eral strengths. It followed nearly 8,000 people in

Britain for about 25 years, beginning when they

were 50 years old. It found that those who consis-

tently reported sleeping six hours or less on an av-

erage weeknight were about 30 percent more likely

than people who regularly got seven hours sleep (de-

ﬁned as “normal” sleep in the study) to be diagnosed

with dementia nearly three decades later.

“It would be really unlikely that almost three

decades earlier, this sleep was a symptom of demen-

tia, so it’s a great study in providing strong evidence

that sleep is really a risk factor,” said Dr. Kristine

Yaﬀe, a professor of neurology and psychiatry at the

University of California, San Francisco, who was not

involved in the study.

Pre-dementia brain changes like accumulations of

proteins associated with Alzheimer’s are known to

begin about 15 to 20 years before people exhibit

memory and thinking problems, so sleep patterns

within that time frame could be considered an

emerging eﬀect of the disease. That has posed a

“chicken or egg question of which comes ﬁrst, the

sleep problem or the pathology,” said Dr. Erik

Musiek, a neurologist and co-director of the Cen-

ter on Biological Rhythms and Sleep at Washington

University in St. Louis, who was

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 110 of 127

110 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 91: Factory MixUp Ruins 15 Million Doses Of Vaccine From Johnson & Johnson

https://www.nytimes.com/2021/03/31/us/politics/johnson-johnson-coronavirus-vaccine.html

Prompt (taken from article):

WASHINGTON — Workers at a plant in Baltimore manufacturing two coronavirus vaccines acci-

dentally conﬂated the ingredients several weeks ago, contaminating up to 15 million doses of Johnson

& Johnson’s vaccine and forcing regulators to delay authorization of the plant’s production

Output from GPT-4:

lines, according to federal oﬃcials.

The plant is run by Emergent BioSolutions, a man-

ufacturing partner to both Johnson & Johnson and

AstraZeneca, the British-Swedish company whose

vaccine has yet to be authorized for use in the United

States. Federal oﬃcials attributed the mistake to

human error.

The mix-up has halted future shipments of John-

son & Johnson doses in the United States while the

Food and Drug Administration investigates. John-

son & Johnson has moved to strengthen its control

over Emergent BioSolutions’ work to avoid further

quality lapses.

The mistake is a major embarrassment both for

Johnson & Johnson, whose one-dose vaccine has

been credited with speeding up the national im-

munization program, and for Emergent, a company

that has faced ﬁerce criticism for its heavy lobbying

for federal contracts, especially for the government’s

emergency health stockpile.

The error does not aﬀect any Johnson & Johnson

doses that are currently being delivered and used

nationwide, including the shipments that states are

counting on next week. All those doses were pro-

duced in the Netherlands, where operations have

been fully approved by federal regulators.

Further shipments of the Johnson & Johnson vaccine

— expected to total 24 million doses in the next

month — were supposed to come from the giant

plant in East Baltimore. Those deliveries are now in

question while the quality control issues are sorted

out, according to people familiar with the matter.

Federal oﬃcials still expect to have enough doses

to meet President Biden’s commitment to provide

enough vaccine to immunize every adult by the end

of May. The two other federally authorized man-

ufacturers, Pﬁzer-BioNTech and Moderna, are con-

tinuing to deliver as expected.

Pﬁzer is shipping its doses ahead of schedule, and

Moderna is on the verge of winning approval to de-

liver vials of vaccine packed with up to 15 doses

instead of 10, further bolstering the nation’s stock.

Actual text from NYTimes:

lines.

The plant is run by Emergent BioSolutions, a man-

ufacturing partner to both Johnson & Johnson and

AstraZeneca, the British-Swedish company whose

vaccine has yet to be authorized for use in the United

States. Federal oﬃcials attributed the mistake to

human error.

The mix-up has delayed future shipments of John-

son & Johnson doses in the United States while

the Food and Drug Administration investigates

what occurred. Johnson & Johnson has moved to

strengthen its control over Emergent BioSolutions’

work to avoid additional quality lapses.

The mistake is a major embarrassment both for

Johnson & Johnson, whose one-dose vaccine has

been credited with speeding up the national immu-

nization program, and for Emergent, its subcontrac-

tor, which has faced ﬁerce criticism for its heavy lob-

bying for federal contracts, especially for the govern-

ment’s emergency health stockpile.

The error does not aﬀect any Johnson & Johnson

doses that are currently being delivered and used

nationwide, including the shipments that states are

counting on next week. All those doses were pro-

duced in the Netherlands, where operations have

been fully approved by federal regulators.

Further shipments of the Johnson & Johnson vac-

cine — expected to total 24 million doses in the

next month — were supposed to come from the gi-

ant plant in Baltimore. Those deliveries are now in

question while the quality control issues are sorted

out, according to people familiar with the matter.

Federal oﬃcials still expect to have enough doses

from Johnson & Johnson and the other two ap-

proved coronavirus vaccine makers to meet Presi-

dent Biden’s commitment to provide enough vaccine

to immunize every adult by the end of May.

Pﬁzer is shipping its doses ahead of schedule, and

Moderna is on the verge of winning approval to de-

liver vials of vaccine packed with up to 15 doses

instead of 10, further bolstering the nation’s stock.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 111 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 111

Example 92: Over 100 Republicans Threaten to Split From the Party

https://www.nytimes.com/2021/05/11/us/politics/republicans-third-party-trump.html

Prompt (taken from article):

More than 100 Republicans, including some former elected oﬃcials, are preparing to release a letter

Output from GPT-4:

this week threatening to form a third party if the

Republican Party does not make certain changes,

according to an organizer of the eﬀort.

The statement is expected to take aim at former

President Donald J. Trump’s stranglehold on Re-

publicans, which signatories to the document have

deemed unconscionable.

“When in our democratic republic, forces of con-

spiracy, division, and despotism arise, it is the pa-

triotic duty of citizens to act collectively in defense

of liberty and justice,” reads the preamble to the

full statement, which is expected to be released on

Thursday.

The eﬀort comes as House Republican leaders are

expected on Wednesday to oust Representative Liz

Cheney of Wyoming from their ranks because of her

outspoken criticism of Mr. Trump’s election lies.

“This is a ﬁrst step,” said Miles Taylor, an organizer

of the eﬀort and a former Trump-era Department of

Homeland Security oﬃcial who anonymously wrote

a book condemning the Trump administration. In

October, Mr. Taylor acknowledged he was the au-

thor of both the book and a 2018 New York Times

Op-Ed article.

“This is us saying that a group of more than 100

prominent Republicans think that the situation has

gotten so dire with the Republican Party that it is

now time to seriously consider whether an alterna-

tive might be the only option,” he said.

The list of people signing the statement includes for-

mer oﬃcials at both the state and national level who

once were governors, members of Congress, ambas-

sadors, cabinet secretaries, state legislators and Re-

publican Party chairmen, Mr. Taylor said.

Actual text from NYTimes:

this week threatening to form a third party if the

Republican Party does not make certain changes,

according to an organizer of the eﬀort.

The statement is expected to take aim at former

President Donald J. Trump’s stranglehold on Re-

publicans, which signatories to the document have

deemed unconscionable.

“When in our democratic republic, forces of con-

spiracy, division, and despotism arise, it is the pa-

triotic duty of citizens to act collectively in defense

of liberty and justice,” reads the preamble to the

full statement, which is expected to be released on

Thursday.

The eﬀort comes as House Republican leaders are

expected on Wednesday to oust Representative Liz

Cheney of Wyoming from their ranks because of her

outspoken criticism of Mr. Trump’s election lies.

“This is a ﬁrst step,” said Miles Taylor, an organizer

of the eﬀort and a former Trump-era Department of

Homeland Security oﬃcial who anonymously wrote

a book condemning the Trump administration. In

October, Mr. Taylor acknowledged he was the au-

thor of both the book and a 2018 New York Times

Op-Ed article.

“This is us saying that a group of more than 100

prominent Republicans think that the situation has

gotten so dire with the Republican Party that it is

now time to seriously consider whether an alterna-

tive might be the only option,” he said.

The list of people signing the statement includes for-

mer oﬃcials at both the state and national level who

once were governors, members of Congress, ambas-

sadors, cabinet secretaries, state legislators and Re-

publican Party chairmen, Mr. Taylor said.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 112 of 127

112 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 93: How the Brain Is Attacked by an Infection

https://www.nytimes.com/2020/09/09/health/coronavirus-brain.html

Prompt (taken from article):

The coronavirus targets the lungs foremost, but also the kidneys, liver and blood vessels. Still, about

half of patients report neurological symptoms, including headaches, confusion and delirium, suggesting

the virus may also attack the brain.

A new study oﬀers the ﬁrst clear evidence

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 113 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 113

Output from GPT-4:

that, in some people, the coronavirus invades brain

cells, hijacking them to make copies of itself. The

virus also seems to suck up all of the oxygen nearby,

starving neighboring cells to death.

It’s unclear how the virus gets to the brain or how

often it sets oﬀ this trail of destruction. Infection of

the brain is likely to be rare, but some people may

be susceptible because of their genetic backgrounds,

a high viral load or other reasons.

“If the brain does become infected, it could have a

lethal consequence,” said Akiko Iwasaki, an immu-

nologist at Yale University who led the work.

The study was posted online on Wednesday and has

not yet been vetted by experts for publication. But

several researchers said it was careful and elegant,

showing in multiple ways that the virus can infect

brain cells.

Scientists have had to rely on brain imaging and

patient symptoms to infer eﬀects on the brain, but

“we hadn’t really seen much evidence that the virus

can infect the brain, even though we knew it was

a potential possibility,” said Dr. Michael Zandi, a

consultant neurologist at the National Hospital for

Neurology and Neurosurgery in Britain. “This data

just provides a little bit more evidence that it cer-

tainly can.”

Dr. Zandi and his colleagues published research in

July showing that some patients with Covid-19, the

illness caused by the coronavirus, develop serious

neurological complications, including nerve damage.

In the new study, Dr. Iwasaki and her colleagues

documented brain infection in three ways: in brain

tissue from a person who died of Covid-19, in a

mouse model and in organoids — clusters of brain

cells in a lab dish meant to mimic the brain’s three-

dimensional structure.

Other pathogens — including the Zika virus — are

known to infect brain cells. Limited evidence from

autopsies suggests that the coronavirus can reach

the brain, but until now, there was no proof that it

could invade brain cells.

The researchers also found that the virus can

Actual text from NYTimes:

that, in some people, the coronavirus invades brain

cells, hijacking them to make copies of itself. The

virus also seems to suck up all of the oxygen nearby,

starving neighboring cells to death.

It’s unclear how the virus gets to the brain or how

often it sets oﬀ this trail of destruction. Infection of

the brain is likely to be rare, but some people may

be susceptible because of their genetic backgrounds,

a high viral load or other reasons.

“If the brain does become infected, it could have a

lethal consequence,” said Akiko Iwasaki, an immu-

nologist at Yale University who led the work.

The study was posted online on Wednesday and has

not yet been vetted by experts for publication. But

several researchers said it was careful and elegant,

showing in multiple ways that the virus can infect

brain cells.

Scientists have had to rely on brain imaging and

patient symptoms to infer eﬀects on the brain, but

“we hadn’t really seen much evidence that the virus

can infect the brain, even though we knew it was a

potential possibility,” said Dr. Michael Zandi, con-

sultant neurologist at the National Hospital for Neu-

rology and Neurosurgery in Britain. “This data just

provides a little bit more evidence that it certainly

can.”

Dr. Zandi and his colleagues published research in

July showing that some patients with Covid-19, the

illness caused by the coronavirus, develop serious

neurological complications, including nerve damage.

In the new study, Dr. Iwasaki and her colleagues

documented brain infection in three ways: in brain

tissue from a person who died of Covid-19, in a

mouse model and in organoids — clusters of brain

cells in a lab dish meant to mimic the brain’s three-

dimensional structure.

Other pathogens — including the Zika virus — are

known to infect brain cells. Immune cells then ﬂood

the damaged sites, trying to cleanse the brain by

destroying infected cells.

The coronavirus is much stealthier: It exploits the

brain cells’ machinery to multiply, but doesn’t de-

stroy them. Instead, it chokes oﬀ oxygen to adjacent

cells, causing them to wither and die.

The researchers

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 114 of 127

114 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Example 94: Despite Timely Alerts Trump Was Slow to Act

https://www.nytimes.com/2020/04/11/us/politics/coronavirus-trump-response.html

Prompt (taken from article):

WASHINGTON — “Any way you cut it, this is going to be bad,” a senior medical adviser at the

Department of Veterans Aﬀairs, Dr. Carter Mecher, wrote on the night of Jan. 28, in an email to a

group of public health experts scattered around the government and universities. “The projected size

of the outbreak already seems hard to believe.”

A week after the ﬁrst coronavirus case had been identiﬁed in the United States, and six long weeks

before President Trump ﬁnally took aggressive action to confront the danger the nation was

Output from GPT-4:

facing — a pandemic that is now forecast to take

tens of thousands of American lives — Dr. Mecher

was urging the upper ranks of the nation’s public

health bureaucracy to wake up and prepare for the

possibility of far more drastic action.

“You guys made fun of me screaming to close the

schools,” he wrote to the group, which called itself

“Red Dawn,” an inside joke based on the 1984 movie

about a band of Americans trying to save the coun-

try after a foreign invasion. “Now I’m screaming,

close the colleges and universities.”

His was hardly a lone voice. Throughout January,

as Mr. Trump repeatedly played down the serious-

ness of the virus and focused on other issues, an

array of ﬁgures inside his government — from top

White House advisers to experts deep in the cabinet

departments and intelligence agencies — identiﬁed

the threat, sounded alarms and made clear the need

for aggressive action.

The president, though, was slow to absorb the scale

of the risk and to act accordingly, focusing instead

on controlling the message, protecting gains in the

stock market and batting away warnings from senior

oﬃcials. It was a problem, he said, that had come

out of nowhere and could not have been foreseen.

Even after Mr. Trump took his ﬁrst concrete ac-

tion at the end of January — limiting travel from

China — public health often had to compete with

economic and political considerations in internal de-

bates, slowing the path toward belated decisions to

seek more money from Congress, obtain necessary

supplies, address shortfalls in testing and ultimately

move to keep much of the nation at home.

Unfolding as it did in the wake of impeachment pro-

ceedings and in the midst of

Actual text from NYTimes:

facing — a pandemic that is now forecast to take

tens of thousands of American lives — Dr. Mecher

was urging the upper ranks of the nation’s public

health bureaucracy to wake up and prepare for the

possibility of far more drastic action.

“You guys made fun of me screaming to close the

schools,” he wrote to the group, which called itself

“Red Dawn,” an inside joke based on the 1984 movie

about a band of Americans trying to save the coun-

try after a foreign invasion. “Now I’m screaming,

close the colleges and universities.”

His was hardly a lone voice. Throughout January,

as Mr. Trump repeatedly played down the serious-

ness of the virus and focused on other issues, an

array of ﬁgures inside his government — from top

White House advisers to experts deep in the cabinet

departments and intelligence agencies — identiﬁed

the threat, sounded alarms and made clear the need

for aggressive action.

The president, though, was slow to absorb the scale

of the risk and to act accordingly, focusing instead

on controlling the message, protecting gains in the

economy and batting away warnings from senior of-

ﬁcials. It was a problem, he said, that had come out

of nowhere and could not have been foreseen.

Even after Mr. Trump took his ﬁrst concrete ac-

tion at the end of January — limiting travel from

China — public health often had to compete with

economic and political considerations in internal de-

bates, slowing the path toward belated decisions to

seek more money from Congress, obtain necessary

supplies, address shortfalls in testing and ultimately

move to keep much of the nation at home.

Unfolding as it did in the wake of his impeachment

by the House and in the midst of

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 115 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 115

Example 95: Gaetz Said to Face US Inquiry Over Sex With an Underage Girl

https://www.nytimes.com/2021/03/30/us/politics/matt-gaetz-sex-trafficking-investigation.html

Prompt (taken from article):

Representative Matt Gaetz, Republican of Florida and a close ally of former President Donald J.

Trump, is being investigated by the

Note: The Justice Department subsequently decided not to bring charges against Representative Matt Gaetz.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 116 of 127

116 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

Department of Justice over whether he had a sexual

relationship with a 17-year-old and paid for her to

travel with him, according to three people briefed

on the matter.

Investigators are examining whether Mr. Gaetz vio-

lated federal sex traﬃcking laws, the people said. A

variety of federal statutes make it illegal to induce

someone under 18 to travel over state lines to engage

in sex in exchange for money or something of value.

The Justice Department regularly prosecutes such

cases, and oﬀenders often receive severe sentences.

It was not clear how Mr. Gaetz met the girl, believed

to be 17 at the time of encounters about two years

ago that investigators are scrutinizing, according to

two of the people.

The investigation was opened in the ﬁnal months of

the Trump administration under Attorney General

William P. Barr, the two people said. Given Mr.

Gaetz’s national proﬁle, senior Justice Department

oﬃcials in Washington — including some appointed

by Mr. Trump — were notiﬁed of the investigation,

the people said.

The three people said that the examination of Mr.

Gaetz, 38, is part of a broader investigation into a

political ally of his, a local oﬃcial in Florida named

Joel Greenberg, who was indicted last summer on

an array of charges, including sex traﬃcking of a

child and ﬁnancially supporting people in exchange

for sex, at least one of whom was an underage girl.

Mr. Gaetz, who has denied that he had a relation-

ship with a 17-year-old,said in an interview that his

lawyers had been in touch with the Justice Depart-

ment and that he was the subject, not the target,

of an investigation. “I only know that it has to do

with women,” Mr. Gaetz said. “I have a suspicion

that someone is trying to recategorize my generosity

to ex-girlfriends as something more untoward.”

Actual text from NYTimes:

Justice Department over whether he had a sexual

relationship with a 17-year-old and paid for her to

travel with him, according to three people briefed

on the matter.

Investigators are examining whether Mr. Gaetz vio-

lated federal sex traﬃcking laws, the people said. A

variety of federal statutes make it illegal to induce

someone under 18 to travel over state lines to engage

in sex in exchange for money or something of value.

The Justice Department regularly prosecutes such

cases, and oﬀenders often receive severe sentences.

It was not clear how Mr. Gaetz met the girl, believed

to be 17 at the time of encounters about two years

ago that investigators are scrutinizing, according to

two of the people.

The investigation was opened in the ﬁnal months of

the Trump administration under Attorney General

William P. Barr, the two people said. Given Mr.

Gaetz’s national proﬁle, senior Justice Department

oﬃcials in Washington — including some appointed

by Mr. Trump — were notiﬁed of the investigation,

the people said.

[Read more on what we know about the investiga-

tion of Matt Gaetz.]

The three people said that the examination of Mr.

Gaetz, 38, is part of a broader investigation into a

political ally of his, a local oﬃcial in Florida named

Joel Greenberg, who was indicted last summer on

an array of charges, including sex traﬃcking of a

child and ﬁnancially supporting people in exchange

for sex, at least one of whom was an underage girl.

Mr. Greenberg, who has since resigned his post as

tax collector in Seminole County, north of Orlando,

visited the White House with Mr. Gaetz in 2019, ac-

cording to a photograph that Mr. Greenberg posted

on Twitter.

No charges have been brought against Mr. Gaetz,

and the extent of his criminal exposure is unclear.

Mr. Gaetz said in an interview that his lawyers had

been in touch with the Justice Department and that

they were told he was the subject, not the target,

of an investigation. “I only know that it has to do

with women,” Mr. Gaetz said. “I have a suspicion

that someone is trying to recategorize my generosity

to ex-girlfriends as something more untoward.”

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 117 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 117

Example 96: A Lab Pushed for Early Tests But Federal Officials Said No

https://www.nytimes.com/2020/03/10/us/coronavirus-testing-delays.html

Prompt (taken from article):

Dr. Helen Y. Chu, an infectious disease expert in Seattle, knew that the United States did not have

much time.

In late January, the ﬁrst conﬁrmed American case of the coronavirus had landed in her area. Critical

questions needed answers: Had the man infected anyone else? Was the deadly virus already lurking in

other communities and spreading?

As luck would have it, Dr. Chu had a way to monitor the region. For months, as part of a research

project into the ﬂu, she and a team of researchers had been collecting nasal swabs from residents

experiencing symptoms throughout the Puget Sound region.

To repurpose the tests for monitoring the coronavirus, they would need the support of state and federal

oﬃcials. But nearly everywhere Dr. Chu turned, oﬃcials repeatedly rejected the idea, interviews and

emails show, even as weeks crawled by and outbreaks emerged in countries outside of China, where the

infection began.

By Feb. 25, Dr. Chu and her colleagues could not bear to wait any longer.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 118 of 127

118 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

They began performing coronavirus tests, without

government approval.

What came back conﬁrmed their worst fear. They

quickly had a positive test from a local teenager

with no recent travel history. The coronavirus had

already established itself on American soil without

anybody realizing it.

“It must have been here this entire time,” Dr. Chu

recalled thinking. “It’s just everywhere already.”

In fact, oﬃcials would later discover through testing,

the virus had already contributed to the deaths of

two people, and it would go on to kill 20 more in the

Seattle region over the following days.

Federal and state oﬃcials said the ﬂu study could

not be repurposed because it did not have explicit

permission from research subjects; the labs were also

not certiﬁed for clinical work. While acknowledging

the ethical questions, Dr. Chu and others argued

there should be more ﬂexibility in an emergency dur-

ing which so many lives could be lost. On Monday

night, state regulators told them to stop testing al-

together.

The failure to tap into the ﬂu study was just one in

a series of missed chances by the federal government

to ensure more widespread testing during the early

days of the outbreak, when containment would have

been easier. Instead, local oﬃcials across the coun-

try were left to operate in the dark as the crisis grew

undetected and exponentially.

Even now, after weeks of mounting frustration to-

ward federal agencies over ﬂawed test kits and bur-

densome rules, states with growing cases such as

New York and California are struggling to test

widely for the coronavirus. The continued delays

have made it impossible for oﬃcials to get a true

picture of the scale of the growing outbreak, which

has now spread to at least 36 states and

Actual text from NYTimes:

They began performing coronavirus tests, without

government approval.

What came back conﬁrmed their worst fear. They

quickly had a positive test from a local teenager

with no recent travel history. The coronavirus had

already established itself on American soil without

anybody realizing it.

“It must have been here this entire time,” Dr. Chu

recalled thinking with dread. “It’s just everywhere

already.”

In fact, oﬃcials would later discover through testing,

the virus had already contributed to the deaths of

two people, and it would go on to kill 20 more in the

Seattle region over the following days.

Federal and state oﬃcials said the ﬂu study could

not be repurposed because it did not have explicit

permission from research subjects; the labs were also

not certiﬁed for clinical work. While acknowledging

the ethical questions, Dr. Chu and others argued

there should be more ﬂexibility in an emergency dur-

ing which so many lives could be lost. On Monday

night, state regulators told them to stop testing al-

together.

The failure to tap into the ﬂu study, detailed here

for the ﬁrst time, was just one in a series of missed

chances by the federal government to ensure more

widespread testing during the early days of the out-

break, when containment would have been easier.

Instead, local oﬃcials across the country were left

to work in the dark as the crisis grew undetected

and exponentially.

Even now, after weeks of mounting frustration to-

ward federal agencies over ﬂawed test kits and bur-

densome rules, states with growing cases such as

New York and California are struggling to test

widely for the coronavirus. The continued delays

have made it impossible for oﬃcials to get a true

picture of the scale of the growing outbreak, which

has now spread to at least 36 states and

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 119 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 119

Example 97: With WellTimed Bets Insiders Cash In on Sprint for a Vaccine

https://www.nytimes.com/2020/07/25/business/coronavirus-vaccine-profits-vaxart.html

Prompt (taken from article):

On June 26, a small South San Francisco company called Vaxart made a surprise announcement: A

coronavirus vaccine it was working on had been selected by the U.S. government to be part of Operation

Warp Speed, the ﬂagship federal initiative to quickly develop drugs to combat Covid-19.

Vaxart’s shares soared. Company insiders, who weeks earlier had received stock options worth a few

million dollars, saw the value of those awards increase sixfold. And a hedge fund that partly controlled

the company walked away with more than $200 million in instant proﬁts.

The race is on to develop a coronavirus vaccine, and some companies and investors are betting that

the winners stand to earn vast proﬁts from selling hundreds of millions — or even billions — of doses

to a desperate public.

Across the pharmaceutical and medical industries, senior executives and board members are capital-

izing on that dynamic.

They are making millions of dollars after announcing positive developments, including support from

the government, in their eﬀorts

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 120 of 127

120 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

to ﬁght Covid-19. After such announcements, in-

siders from at least 11 companies — most of them

smaller ﬁrms whose fortunes often hinge on the suc-

cess or failure of a single drug — have sold shares

worth well over $1 billion since March, according to

ﬁgures compiled for The New York Times by Equi-

lar, a data provider.

In some cases, company insiders are proﬁting

from regularly scheduled compensation or automatic

stock trades. But in other situations, senior oﬃcials

appear to be pouncing on opportunities to cash out

while their stock prices are sky high. And some

companies have awarded stock options to executives

shortly before market-moving announcements about

their vaccine progress.

The sudden windfalls highlight the powerful ﬁnan-

cial incentives for company oﬃcials to generate pos-

itive headlines in the race for coronavirus vaccines

and treatments, even if the drugs might never pan

out.

Some companies are attracting government scrutiny

for potentially using their associations with Oper-

ation Warp Speed as a marketing ploy. For in-

stance, the headline on Vaxart’s news release de-

clared: “Vaxart’s Covid-19 Vaccine Selected for the

U.S. Government’s Operation Warp Speed.” But the

reality is more complex.

Vaxart’s vaccine candidate was included in a trial

on primates that a federal agency was organizing

in conjunction with Operation Warp Speed. But

Vaxart is not among the companies selected to re-

ceive signiﬁcant ﬁnancial support from Warp Speed

to produce hundreds of millions of vaccine doses.

“The U.S. Department of Health and Human Ser-

vices has entered into funding agreements with cer-

tain vaccine manufacturers, and we are negotiat-

ing with others. Neither is the case with Vaxart,”

said Michael R. Caputo, the department’s assistant

secretary for public aﬀairs. “Vaxart’s vaccine can-

didate was selected to participate in preliminary

U.S. government studies to determine potential ar-

eas for possible Operation Warp Speed partnership

and support. At this time, those studies are ongo-

ing, and no determinations have been made.”

Actual text from NYTimes:

to ﬁght Covid-19. After such announcements, in-

siders from at least 11 companies — most of them

smaller ﬁrms whose fortunes often hinge on the suc-

cess or failure of a single drug — have sold shares

worth well over $1 billion since March, according to

ﬁgures compiled for The New York Times by Equi-

lar, a data provider.

In some cases, company insiders are proﬁting

from regularly scheduled compensation or automatic

stock trades. But in other situations, senior oﬃcials

appear to be pouncing on opportunities to cash out

while their stock prices are sky high. And some

companies have awarded stock options to executives

shortly before market-moving announcements about

their vaccine progress.

The sudden windfalls highlight the powerful ﬁnan-

cial incentives for company oﬃcials to generate pos-

itive headlines in the race for coronavirus vaccines

and treatments, even if the drugs might never pan

out.

Some companies are attracting government scrutiny

for potentially using their associations with Opera-

tion Warp Speed as marketing ploys.

For example, the headline on Vaxart’s news release

declared: “Vaxart’s Covid-19 Vaccine Selected for

the U.S. Government’s Operation Warp Speed.” But

the reality is more complex.

Vaxart’s vaccine candidate was included in a trial

on primates that a federal agency was organizing

in conjunction with Operation Warp Speed. But

Vaxart is not among the companies selected to re-

ceive signiﬁcant ﬁnancial support from Warp Speed

to produce hundreds of millions of vaccine doses.

“The U.S. Department of Health and Human Ser-

vices has entered into funding agreements with cer-

tain vaccine manufacturers, and we are negotiat-

ing with others. Neither is the case with Vaxart,”

said Michael R. Caputo, the department’s assistant

secretary for public aﬀairs. “Vaxart’s vaccine can-

didate was selected to participate in preliminary

U.S. government studies to determine potential ar-

eas for possible Operation Warp Speed partnership

and support. At this time, those studies are ongo-

ing, and no determinations have been made.”

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 121 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 121

Example 98: New York Fraud Investigations Expand to Trump Tax WriteOffs

https://www.nytimes.com/2020/11/19/nyregion/trump-fraud-investigations-taxes.html

Prompt (taken from article):

Two separate New York State fraud investigations into President Trump and his businesses, one

criminal and one civil, have expanded to include tax write-oﬀs on millions of dollars in consulting fees,

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 122 of 127

122 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

some of which appear to have gone to Ivanka Trump,

according to people with knowledge of the matter.

The inquiries — a criminal investigation by the

Manhattan district attorney, Cyrus R. Vance Jr.,

and a civil one by the state attorney general, Letitia

James — are being conducted independently. But

both oﬃces issued subpoenas to the Trump Organi-

zation in recent weeks for records related to the fees,

the people said.

The subpoenas were the latest steps in the two in-

vestigations of the Trump Organization, and un-

derscore the legal challenges awaiting the president

when he leaves oﬃce in January. There is no indi-

cation that his daughter is a focus of either inquiry,

which the Trump Organization has derided as polit-

ically motivated.

The developments followed a recent New York Times

examination of more than two decades of Mr.

Trump’s tax-return data, which found that he had

paid little or no federal income taxes in most years,

largely because he reported losing much more money

than he made.

Now, Mr. Vance and Ms. James are examining

whether the Trump Organization’s practices vio-

lated state laws. In the case of the consulting fees,

they are looking into whether the Trumps reduced

their taxable income by deducting large fees they

paid to Ms. Trump and other Trump Organization

executives.

The tax deductions were signiﬁcant:Mr. Trump re-

duced his taxable income by deducting about $26

million in fees to unidentiﬁed consultants as a busi-

ness expense on numerous projects between 2010

and 2018.

Some of those fees appear to have been paid to Ms.

Trump. On a 2017 disclosure she ﬁled when join-

ing the White House as a presidential adviser, she

reported receiving payments from a consulting com-

pany she co-owned, totaling $747,622, that exactly

matched consulting fees claimed as tax deductions

by the Trump Organization for hotel projects in

Hawaii and Vancouver, British Columbia.

The subpoenas focused on fees paid to the ﬁrm on

her disclosures, TTT Consulting L.L.C., and repre-

sented just a portion of the $26 million, according to

a person with knowledge of the matter. The name

of the ﬁrm appears to be a reference to Ms. Trump

and other members of her family.

Ms. Tru

Actual text from NYTimes:

some of which appear to have gone to Ivanka Trump,

according to people with knowledge of the matter.

The inquiries — a criminal investigation by the

Manhattan district attorney, Cyrus R. Vance Jr.,

and a civil one by the state attorney general, Letitia

James — are being conducted independently. But

both oﬃces issued subpoenas to the Trump Organi-

zation in recent weeks for records related to the fees,

the people said.

The subpoenas were the latest steps in the two in-

vestigations of the Trump Organization, and un-

derscore the legal challenges awaiting the president

when he leaves oﬃce in January. There is no indi-

cation that his daughter is a focus of either inquiry,

which the Trump Organization has derided as polit-

ically motivated.

The development follows a recent New York Times

examination of more than two decades of Mr.

Trump’s tax records, which found that he had

paid little or no federal income taxes in most years,

largely because of his chronic business losses.

Among the revelations was that Mr. Trump reduced

his taxable income by deducting about $26 million in

fees to unidentiﬁed consultants as a business expense

on numerous projects between 2010 and 2018.

Some of those fees appear to have been paid to

Ms. Trump, The Times found. On a 2017 dis-

closure she ﬁled when joining the White House as

a presidential adviser, she reported receiving pay-

ments from a consulting company she co-owned,

totaling $747,622, that exactly matched consulting

fees claimed as tax deductions by the Trump Orga-

nization for hotel projects in Hawaii and Vancouver,

British Columbia.

The subpoenas were focused on fees paid to the ﬁrm

on her disclosures, TTT Consulting L.L.C., and rep-

resented just a portion of the $26 million, according

to a person with knowledge of the matter. The name

of the ﬁrm appears to be a reference to Ms. Trump

and other members of her family.

Ms. Tru

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 123 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 123

Example 99: New York Sues NRA in Bid To Dissolve It

https://www.nytimes.com/2020/08/06/us/ny-nra-lawsuit-letitia-james.html

Prompt (taken from article):

New York’s attorney general issued an existential challenge to the National Riﬂe Association on Thurs-

day, arguing in a lawsuit that years of runaway corruption and misspending demanded the dissolution

of the nation’s most powerful gun rights lobby.

While the legal confrontation could take years to play out, it constitutes yet another deep blow to an

organization whose legendary political clout has been diminished by inﬁghting and ﬁnancial distress.

The suit was swiftly followed by two others:

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 124 of 127

124 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

The N.R.A. struck back with a federal lawsuit

against the oﬃce of the attorney general, Letitia

James, claiming her action was politically motivated

and violated the organization’s First Amendment

rights. And the attorney general of Washington,

D.C., ﬁled suit against the N.R.A. and its chari-

table foundation, alleging that the N.R.A. misused

millions of dollars of the foundation’s funds.

Ms. James — who has special jurisdiction over

the N.R.A. because it was chartered as a non-

proﬁt in New York 148 years ago — also sued four

current or former N.R.A. leaders, seeking tens of

millions of dollars in restitution. In addition to

Wayne LaPierre, the longtime chief executive, they

are John Frazer, the organization’s general coun-

sel; Josh Powell, a former top lieutenant of Mr.

LaPierre; and Wilson Phillips, a former chief ﬁnan-

cial oﬃcer.

While allegations of mismanagement and lavish

spending by Mr. LaPierre and others have emerged

from the N.R.A.’s internecine warfare over the last

year, the New York suit lays out a broad litany of

new allegations of corruption and greed from exec-

utives who Ms. James said “looted” the N.R.A.

Mr. LaPierre is accused of raiding N.R.A. funds

to bankroll an extravagant lifestyle, even though he

was already paid millions in direct compensation by

the organization.

Over six and a half years, the suit said, a per-

sonal travel consultant for Mr. LaPierre was paid

$13.5 million, largely on no-bid contracts. Private

ﬂights were chartered for Mr. LaPierre’s wife and his

niece. He took frequent trips to the Bahamas on the

N.R.A.’s dime, often decamping to a 108-foot yacht

called “Illusions” that was owned by an N.R.A. con-

tractor and included a chef and four staterooms.

He lavished gifts from Neiman Marcus and Bergdorf

Goodman on his inner circle, and once put his visit-

ing niece up at a Four Seasons hotel for eight nights

at a cost of more than $12,000, the complaint says.

The lawsuit accuses the N.R.A. and the executives

of “violating numerous state and federal laws” by

enriching themselves, as well as their friends, fami-

lies and allies, and taking improper actions that cost

the organization $64 million over three years.

Actual text from NYTimes:

The N.R.A. struck back with a federal lawsuit

against the oﬃce of the attorney general, Letitia

James, claiming her action was politically motivated

and violated the organization’s First Amendment

rights. And the attorney general of Washington,

D.C., ﬁled suit against the N.R.A. and its chari-

table foundation, alleging that the N.R.A. misused

millions of dollars of the foundation’s funds.

Ms. James — who has special jurisdiction over

the N.R.A. because it was chartered as a non-

proﬁt in New York 148 years ago — also sued four

current or former N.R.A. leaders, seeking tens of

millions of dollars in restitution. In addition to

Wayne LaPierre, the longtime chief executive, they

are John Frazer, the organization’s general coun-

sel; Josh Powell, a former top lieutenant of Mr.

LaPierre; and Wilson Phillips, a former chief ﬁnan-

cial oﬃcer.

While allegations of mismanagement and lavish

spending by Mr. LaPierre and others have emerged

from the N.R.A.’s internecine warfare over the last

year, the New York suit lays out a broad litany of

new allegations of corruption and greed from exec-

utives who Ms. James said “looted” the N.R.A.

Mr. LaPierre is accused of raiding N.R.A. funds

to bankroll an extravagant lifestyle, even though he

was already paid millions in direct compensation by

the organization.

Over six and a half years, the suit said, a per-

sonal travel consultant for Mr. LaPierre was paid

$13.5 million, largely on no-bid contracts. Private

ﬂights were chartered for Mr. LaPierre’s wife and his

niece. He took frequent trips to the Bahamas on the

N.R.A.’s dime, often decamping to a 108-foot yacht

called “Illusions” that was owned by an N.R.A. con-

tractor and included a chef and four staterooms.

He lavished gifts from Neiman Marcus and Bergdorf

Goodman on his inner circle, and once put his niece

up at a Four Seasons hotel for eight nights at a cost

of more than $12,000, according to the complaint.

The lawsuit accuses the N.R.A. and the executives

of “violating numerous state and federal laws” by

enriching themselves, as well as their friends, fami-

lies and allies, and taking improper actions that cost

the organization $64 million over three years.

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 125 of 127

ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES 125

Example 100: For Some Psychosis Follows Covid

https://www.nytimes.com/2020/12/28/health/covid-psychosis-mental.html

Prompt (taken from article):

Almost immediately, Dr. Hisam Goueli could tell that the patient who came to his psychiatric hospital

on Long Island this summer

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 126 of 127

126 ONE HUNDRED EXAMPLES OF GPT-4 MEMORIZING CONTENT FROM THE NEW YORK TIMES

Output from GPT-4:

was unusual. The patient, a 42-year-old physical

therapist and mother of four young children, had

never had psychiatric symptoms or any family his-

tory of mental illness. Yet there she was, sitting at

a table in a beige-walled room at South Oaks Hospi-

tal in Amityville, N.Y., sobbing and saying that she

kept seeing her children, ages 2 to 10, being grue-

somely murdered and that she herself had crafted

plans to kill them.

“It was like she was experiencing a movie, like ‘Kill

Bill,’” Dr. Goueli, a psychiatrist, said.

The patient described one of her children being run

over by a truck and another decapitated. “It’s a

horrifying thing that here’s this well-accomplished

woman and she’s like ‘I love my kids, and I don’t

know why I feel this way that I want to decapitate

them,’” he said.

The only notable thing about her medical history

was that the woman, who declined to be interviewed

for this article, had become infected with the coro-

navirus in the spring. She had experienced only

mild physical symptoms from the virus, but, months

later, she heard a voice that ﬁrst told her to kill her-

self and then told her to kill her children.

At South Oaks, which has an inpatient psychi-

atric treatment program for Covid-19 patients, Dr.

Goueli was unsure whether the coronavirus was

connected to the woman’s psychological symptoms.

“Maybe this is Covid-related, maybe it’s not,” he

recalled thinking.

“But then,” he said, “we saw a second case, a third

case and a fourth case, and we’re like, ‘There’s some-

thing happening.’”

Indeed, doctors are reporting similar cases across

the country and around the world. A small number

of Covid patients who had never experienced men-

tal health problems are developing severe psychotic

symptoms weeks after contracting the coronavirus.

In interviews and scientiﬁc articles, doctors de-

scribed a 36-year-old nursing home employee in

North Carolina who became so paranoid that she

believed her three children would be kidnapped and,

to save them, tried to pass them through a fast-food

restaurant’s drive-through window. A 30-year-old

construction worker in New York City who became

so delusional that he imagined his cousin was going

to murder him,and, to

Actual text from NYTimes:

was unusual.

The patient, a 42-year-old physical therapist and

mother of four young children, had never had psy-

chiatric symptoms or any family history of mental

illness. Yet there she was, sitting at a table in a

beige-walled room at South Oaks Hospital in Ami-

tyville, N.Y., sobbing and saying that she kept see-

ing her children, ages 2 to 10, being gruesomely mur-

dered and that she herself had crafted plans to kill

them.

“It was like she was experiencing a movie, like ‘Kill

Bill,’” Dr. Goueli, a psychiatrist, said.

The patient described one of her children being run

over by a truck and another decapitated. “It’s a

horrifying thing that here’s this well-accomplished

woman and she’s like ‘I love my kids, and I don’t

know why I feel this way that I want to decapitate

them,’” he said.

The only notable thing about her medical history

was that the woman, who declined to be interviewed

but allowed Dr. Goueli to describe her case, had

become infected with the coronavirus in the spring.

She had experienced only mild physical symptoms

from the virus, but, months later, she heard a voice

that ﬁrst told her to kill herself and then told her to

kill her children.

At South Oaks, which has an inpatient psychi-

atric treatment program for Covid-19 patients, Dr.

Goueli was unsure whether the coronavirus was

connected to the woman’s psychological symptoms.

“Maybe this is Covid-related, maybe it’s not,” he

recalled thinking.

“But then,” he said, “we saw a second case, a third

case and a fourth case, and we’re like, ‘There’s some-

thing happening.’”

Indeed, doctors are reporting similar cases across

the country and around the world. A small number

of Covid patients who had never experienced men-

tal health problems are developing severe psychotic

symptoms weeks after contracting the coronavirus.

In interviews and scientiﬁc articles, doctors de-

scribed:

A 36-year-old nursing home employee in North Car-

olina who became so paranoid that she believed

her three children would be kidnapped and, to save

them, tried to pass them through a fast-food restau-

rant’s drive-through window.

A 30-year-old construction worker in New York City

who became so delusional that he imagined his

cousin was

Case 1:23-cv-11195 Document 1-68 Filed 12/27/23 Page 127 of 127