Model: llm-wizard/legal-ft-arctic-l
Author: llm-wizard
Pipeline: sentence-similarity
Library: sentence-transformers
Tags: sentence-transformers, safetensors, bert, sentence-similarity, feature-extraction, generated_from_trainer, dataset_size:400, loss:MatryoshkaLoss, loss:MultipleNegativesRankingLoss, arxiv:1908.10084, arxiv:2205.13147, arxiv:1705.00652, base_model:Snowflake/snowflake-arctic-embed-l, base_model:finetune:Snowflake/snowflake-arctic-embed-l, model-index, text-embeddings-inference, endpoints_compatible, region:us
Base models (finetune): id: Snowflake/snowflake-arctic-embed-l
Card metadata: base_model: Snowflake/snowflake-arctic-embed-l
library_name: sentence-transformers
metrics: cosine_accuracy@1, cosine_accuracy@3, cosine_accuracy@5, cosine_accuracy@10, cosine_precision@1, cosine_precision@3, cosine_precision@5, cosine_precision@10, cosine_recall@1, cosine_recall@3, cosine_recall@5, cosine_recall@10, cosine_ndcg@10, cosine_mrr@10, cosine_map@100, dot_accuracy@1, dot_accuracy@3, dot_accuracy@5, dot_accuracy@10, dot_precision@1, dot_precision@3, dot_precision@5, dot_precision@10, dot_recall@1, dot_recall@3, dot_recall@5, dot_recall@10, dot_ndcg@10, dot_mrr@10, dot_map@100
pipeline_tag: sentence-similarity
tags: sentence-transformers, sentence-similarity, feature-extraction, generated_from_trainer, dataset_size:400, loss:MatryoshkaLoss, loss:MultipleNegativesRankingLoss
widget: source_sentence: What does it mean for a decision to not be considered arbitrary and capricious according to the provided context?
sentences: Aravind Srinivas, Founding Story and Journey of Perplexity, YOUTUBE, at 17:57 (Jan. 18, 2024), 
https://www.youtube.com/watch?v=ygRVDIwheB4. 
17 See, e.g., Avoiding Plagiarism Guide, APA Style 7th Edition (last visited Aug. 30, 2024), 
https://apastyle.apa.org/instructional-aids/avoiding-plagiarism.pdf. 
18 See What is Perplexity?, supra note 1 (promoting Perplexity’s “Reliable sources” with an 
explanation that “[e]very answer is backed by citations from trusted news outlets, academic papers, 
and established blogs”).  
19 Madhumita Murgia & Cristina Criddle, Perplexity’s popularity surges as AI search start-up takes 
on Google, THE FINANCIAL TIMES (Aug. 9, 2024), https://www.ft.com/content/87af3340-2611-
4650-9ae3-036927e9f65c., 30 
 
Serv. Comm'n, 43 Mass. App. Ct. 300, 303 (1997). A decision is not arbitrary and capricious if 
"reasonable minds could differ" on the proper outcome. See Kinchla v. Board of Appeals of 
Falmouth, 11 Mass. App. Ct. 927, 927 (1981). 
In determining the appropriate definition of general words used in a statute, the courts may 
look to sources outside the statute such as "their use in other legal contexts: and dictionary 
definitions." See Commonwealth v. Correia, 17 Mass.App.Ct. 233, 235 (1983) “Arbitrary” is 
defined as subject to individual will or judgment without restriction; contingent solely upon one's 
discretion… having unlimited power; uncontrolled or unrestricted by law; despotic; tyrannical;, purpose of providing a substitute product.    
Case 1:24-cv-07984     Document 1     Filed 10/21/24     Page 3 of 42, source_sentence: What percentage of applicants were admitted to Stanford last year?
sentences: to which RNH is currently applying are extremely competitive and the admissions process for 
admission into such schools is rigorous.  These schools command an extensive applicant pool of 
high academic achievers with high test scores, grade point averages, including grades of A’s and 
B’s only.  Stanford is one of the most competitive schools in the country. Last year, 4% of the 
applicant pool were admitted.  Thousands of extremely well qualified, who elsewhere would be 
highly admissible, were denied. It is essential that any applicant have the most competitive 
transcript possible. A C+ is a red flag that will be noticed far more quickly and glaringly than the 
Case 1:24-cv-12437-WGY   Document 8   Filed 10/08/24   Page 6 of 42, 18 
 
upon in affirming the decision through an appeal to exclude RNH and his classmate from the NHS.  
Id. at ¶145.  At that time, Defendant Swanson and other Defendants knew or should have known 
that the District inducted at least seven students into NHS, who had academic infractions on their 
record, one of which was because of the prior use of AI.  Id. at ¶146.   
The “committee” that adjudicated selection for NHS this year did not include teachers who 
know and are familiar with RNH and his classmate.  Id. at ¶147.  This is due to the then escalating 
contract conflict with the Hingham Educators Association (“HEA”) where HEA engaged in an, 42 
 
CERTIFICATE OF SERVICE 
 
I, Peter S. Farrell, hereby certify that I served a copy of the foregoing on all counsel of 
record pursuant to Local Rule 5.4(c) by causing a copy of the same to be electronically filed and 
served through the CM/ECF filing system to: 
 
Gareth W. Notis, Esquire 
Morrison Mahoney LLP 
250 Summer Street 
Boston, MA 02210 
gnotis@morrisonmahoney.com 
 
 
 
 
 
 
 
 
______________________________ 
 
 
 
 
 
 
Peter S. Farrell 
 
Case 1:24-cv-12437-WGY   Document 8   Filed 10/08/24   Page 42 of 42, source_sentence: What is the case number for the document filed on 10/08/24?
sentences: Case 1:24-cv-07984     Document 1     Filed 10/21/24     Page 19 of 42, Case 1:24-cv-12437-WGY   Document 8   Filed 10/08/24   Page 33 of 42, 11 See, e.g., Elizabeth Lopatto, Perplexity’s Grand Theft AI, THE VERGE (June 27, 2024), 
https://www.theverge.com/2024/6/27/24187405/perplexity-ai-twitter-lie-plagiarism 
(describing 
Perplexity as a “rent-seeking middleman on high-quality sources” that “starve[s] the primary 
source of ad revenue”); Dhruv Mehrotra & Tim Marchman, Perplexity Is a Bullsh*t Machine, 
WIRED 
(June 
19, 
2024), 
https://www.wired.com/story/perplexity-is-a-bullshit-machine 
(discussing Perplexity’s reliance on recent news articles for its content as well as its tendency to 
falsely attribute information) (asterisk added); Casey Newton, How to Stop Perplexity and save 
the web from bad AI, PLATFORMER (June 20, 2024), https://www.platformer.news/how-to-stop-, source_sentence: How does Perplexity gather and compile information from authoritative sources?
sentences: utilize have been trained. To employ a RAG system, AI applications typically utilize indexed 
databases that house all the content from which the AI application will retrieve specific information 
to generate outputs for its users. The larger the index, the more “answers” the AI application can 
provide.  
51. 
In Perplexity’s words, it “scours the internet, gathering information from 
authoritative sources like articles, websites, and journals.”6 It then, “compiles the most relevant 
insights into a coherent, easy-to-understand answer” automatically generated from those original 
sources.7  
52. 
The assembling of authoritative sources for a RAG index is a distinct process from, 9 
26. 
Perplexity processes subscription purchases from customers in this State and 
District, transmits Plaintiffs’ copyrighted content to users in this State and District, and has a 
significant number of customers in this State and District. 
27. 
As a direct and proximate result of Perplexity’s unauthorized use and/or 
dissemination of Plaintiffs’ copyrighted works and trademarks in New York and elsewhere, 
Plaintiffs have lost and will continue to lose revenue and profits from the market for content 
licensing, subscribers, visitors, and users. 
FACTUAL ALLEGATIONS 
I. 
Plaintiffs’ Robust Businesses and Copyrighted Works 
28. 
Dow Jones began in 1882 as a niche news agency in a Wall Street basement,, 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 
DOW JONES & COMPANY, INC.  
and NYP HOLDINGS, INC., 
 
Plaintiffs, 
 
v. 
 
PERPLEXITY AI, INC., 
 
Defendant. 
 
 
 
Civil Action No. 24-cv-7984 
 
 
COMPLAINT 
 
JURY TRIAL DEMANDED  
 
Plaintiffs Dow Jones & Company, Inc. (“Dow Jones”) and NYP Holdings, Inc. (“NYP 
Holdings”) (collectively, “Plaintiffs”), by and through their attorneys, Torridon Law PLLC, for 
their Complaint, hereby allege against Defendant Perplexity AI, Inc. (“Perplexity” or 
“Defendant”), as follows: 
NATURE OF THE ACTION 
1. 
Perplexity is a generative artificial intelligence company that claims to provide its, source_sentence: What recent partnership did News Corp enter into regarding licensing content for OpenAI's applications?
sentences: integrity infractions.   Plain and simple.  It should not take the Plaintiffs engaging counsel, 
demanding information and forcing Hingham to investigate this matter to reveal that selection for 
NHS was a manipulated sham conducted by the Defendants, who at all times relevant were state 
actors. 
C. The Student Will Suffer Irreparable Harm If The Injunction is Not Granted 
In order for the Plaintiffs to obtain injunctive relief, they must show that they are "likely to 
suffer irreparable injury before a decision is rendered on the merits." See Philips Elecs. N. Am. 
Corp. v. Halperin, 2000 Mass. Super LEXIS 574 citing Sierra Club v. Larson, 769 F. Supp. 420,, licensing initiatives abound.”3 For example, News Corp recently partnered with OpenAI to license 
its content for certain uses in OpenAI’s applications. OpenAI users will have the benefit of 
accessing Plaintiffs’ content, whether quoted or summarized by OpenAI. This cooperative 
relationship will allow OpenAI and Plaintiffs to experiment with new product experiences and 
revenue models. 
15. 
Generative AI technology can be developed in two ways. It can be developed 
legally by recognizing the legitimate rights of copyright holders and by including in the AI business 
model the legitimate costs and benefits of licensing the copyrighted material, or it can be developed, ban or prohibition on the use of AI by students. The Defendants were not trained on any policies 
or procedures for use of AI alone, never mind what they were “able to do” to students who used 
it.    The entire purpose behind having such policies and procedures in place is to ensure notice, 
equity, fairness and to be sure:  a level playing field for all.   Making matters worse, there exists 
no adequate procedures and policies for the induction of an applicant into NHS when compared to 
other members who are inducted despite the same or similar infractions.  This is a denial of student 
rights of the highest order. 
 
In the case here, RNH was disciplined on an ad hoc and on-going basis over more than six
model-index: name: SentenceTransformer based on Snowflake/snowflake-arctic-embed-l
results: task: type: information-retrieval
name: Information Retrieval
dataset: name: Unknown
type: unknown
metrics: type: cosine_accuracy@1
value: 0.6875
name: Cosine Accuracy@1
verified: no, type: cosine_accuracy@3
value: 0.8541666666666666
name: Cosine Accuracy@3
verified: no, type: cosine_accuracy@5
value: 0.9583333333333334
name: Cosine Accuracy@5
verified: no, type: cosine_accuracy@10
value: 0.9791666666666666
name: Cosine Accuracy@10
verified: no, type: cosine_precision@1
value: 0.6875
name: Cosine Precision@1
verified: no, type: cosine_precision@3
value: 0.28472222222222215
name: Cosine Precision@3
verified: no, type: cosine_precision@5
value: 0.19166666666666665
name: Cosine Precision@5
verified: no, type: cosine_precision@10
value: 0.09791666666666665
name: Cosine Precision@10
verified: no, type: cosine_recall@1
value: 0.6875
name: Cosine Recall@1
verified: no, type: cosine_recall@3
value: 0.8541666666666666
name: Cosine Recall@3
verified: no, type: cosine_recall@5
value: 0.9583333333333334
name: Cosine Recall@5
verified: no, type: cosine_recall@10
value: 0.9791666666666666
name: Cosine Recall@10
verified: no, type: cosine_ndcg@10
value: 0.8280840444145441
name: Cosine Ndcg@10
verified: no, type: cosine_mrr@10
value: 0.7793650793650793
name: Cosine Mrr@10
verified: no, type: cosine_map@100
value: 0.7812590187590187
name: Cosine Map@100
verified: no, type: dot_accuracy@1
value: 0.6875
name: Dot Accuracy@1
verified: no, type: dot_accuracy@3
value: 0.8541666666666666
name: Dot Accuracy@3
verified: no, type: dot_accuracy@5
value: 0.9583333333333334
name: Dot Accuracy@5
verified: no, type: dot_accuracy@10
value: 0.9791666666666666
name: Dot Accuracy@10
verified: no, type: dot_precision@1
value: 0.6875
name: Dot Precision@1
verified: no, type: dot_precision@3
value: 0.28472222222222215
name: Dot Precision@3
verified: no, type: dot_precision@5
value: 0.19166666666666665
name: Dot Precision@5
verified: no, type: dot_precision@10
value: 0.09791666666666665
name: Dot Precision@10
verified: no, type: dot_recall@1
value: 0.6875
name: Dot Recall@1
verified: no, type: dot_recall@3
value: 0.8541666666666666
name: Dot Recall@3
verified: no, type: dot_recall@5
value: 0.9583333333333334
name: Dot Recall@5
verified: no, type: dot_recall@10
value: 0.9791666666666666
name: Dot Recall@10
verified: no, type: dot_ndcg@10
value: 0.8280840444145441
name: Dot Ndcg@10
verified: no, type: dot_mrr@10
value: 0.7793650793650793
name: Dot Mrr@10
verified: no, type: dot_map@100
value: 0.7812590187590187
name: Dot Map@100
verified: no
Likes: 0 | All-time downloads: 112
Created: 2024-10-22 20:39:03