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Comparative jurisdictional memo · Training-Data Rights

EU AI Act vs Interim Measures for Generative AI Service Management

Verdict: asymmetricDownload PDF

What this comparison shows

On the topic of Training-Data Rights, EU AI Act is classified as implicit and Interim Measures for Generative AI Service Management as governs. The editorial verdict is asymmetric. One regime addresses the topic explicitly while the other covers it only implicitly or not at all; this is a likely site of regulatory arbitrage and a candidate for comparative-law follow-up.

Contested question: Does the EU CDSM Directive's TDM-exemption cover commercial foundation-model training? Major active litigation (NYT v OpenAI, Getty v Stability) and parallel claim regimes in UK/JP/US.

Bibliography

  1. Regulation (EU) 2024/1689 EU AI Act.
  2. CAC Order No. 15 Interim Measures for Generative AI Service Management.
  3. Policy Window — Training-Data Rights (cross-jurisdiction topic article with full 26-instrument coverage matrix).

Catalog-derived comparison. Generated . No LLM-generated prose — all classifications + citations come from the typed catalog at src/lib/international-governance/instruments.ts. How this is made.

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