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Enforcement timeline
Chronologically-ordered enforcement actions linked to the instruments and topics tracked in the Policy Window catalog. Closed cases sort by their resolution year; ongoing cases sort by initiation. Each entry links to the catalog topics + the catalog instruments the case touches, and (where possible) to the best-available primary source for the action.
13 catalogued cases total · 2 match the current filter (year = 2023; topic = Foundation Models / GPAI; instrument = Executive Order 14110 on Safe, Secure, Trustworthy AI) clear all.
Filters
Cases (2)
- Ongoing
- Open arrow = ongoing (no resolution year yet)
- Ongoing
2023 → ongoing · US
FTC investigation of OpenAI
Enforcer: Federal Trade Commission
Target: OpenAI
Violation alleged: Civil Investigative Demand alleging consumer-protection violations: misleading claims about ChatGPT capabilities, training-data privacy, and consumer harm from hallucinations.
Lesson: First US federal enforcement action against a frontier-AI developer. Establishes that pre-AI-statute consumer-protection authority (FTC §5) can be applied to AI services — supports the US 'sectoral / ex-post liability' regime (vs EU's ex-ante AIA). Action remains pending; no judgment yet.
Source: https://www.washingtonpost.com/technology/2023/07/13/ftc-openai-chatgpt-sam-altman-lina-khan/news secondary
- Ongoing
2023 → ongoing · US
New York Times v. OpenAI + Microsoft
Enforcer: New York Times Company (private civil litigation)
Target: OpenAI Inc. + Microsoft Corp.
Violation alleged: Unauthorised reproduction of NYT-copyrighted articles in GPT training corpora; output of substantially similar text on prompted query; removal of copyright-management information.
Lesson: First major frontier-foundation-model copyright lawsuit by a primary news source. Discovery has surfaced disclosure of training-data composition that the EU AIA Art. 53 transparency requirements would have surfaced ex-ante. The case is the highest-stakes ex-post-liability action testing whether US sectoral approach can substitute for ex-ante regulation on training-data rights — outcome will inform 2025-2027 regulatory debates.
Source: https://www.nytimes.com/2023/12/27/business/media/new-york-times-open-ai-microsoft-lawsuit.html
Editorial scope
This timeline reflects enforcement cases tracked in the Policy Window catalog. It is not exhaustive; coverage focuses on high-precedent matters relevant to the catalogued instruments (currently 13 cases across EU, US, UK, China, India, Italy, France). The catalog deliberately omits routine regulator letters and ongoing investigations whose materials are not public.
For the inclusion rubric (when a case enters the catalog, what level of source-defensibility is required, how jurisdictional balance is managed), see /wiki/methodology. Cases marked “ongoing” remain editorial-watch items; outcomes get backfilled as the public record settles.