Large language models can reproduce memorized text verbatim, yet copyright defenses are usually evaluated under incompatible protocols. We introduce CopyShield, a controlled benchmark comparing three representative defenses at distinct intervention levels: contrastive decoding (output), Direct Preference Optimization (behavioral), and activation intervention (representation). We evaluate CopyShield on two model families, LLaMA-3.1-8B and Mistral-7B-v0.3, using controlled memorization over five public-domain books and a shared protocol measuring literal leakage, calibrated non-literal leakage, utility, and degeneracy. Across these methods, intervention level is associated with distinct compliance-utility trade-offs. On LLaMA-3.1-8B, contrastive decoding remains near-degeneracy-free (0-2%) but reaches a literal-suppression floor at NV-Recall 0.192-0.203. DPO nearly eliminates literal leakage (0.263 to 0.002) but induces paraphrase-loop degeneracy in 58% of QA outputs, with no utility gain over the SFT baseline. Activation intervention attains the lowest non-literal flagging rate (1/200) by blocking 84% of non-literal queries before generation. Human evaluation confirms that DPO has low coherence, whereas activation lowers perceived copyright risk through broad refusal. On Mistral-7B-v0.3, the output- and representation-level patterns persist, while DPO degeneracy falls to 10-14%, showing that its severity is model-dependent. Together, CopyShield provides cross-level reference baselines and identifies targeted non-literal suppression as an open challenge. The code is available at https://github.com/spotai-mbzuai/CopyShield.git.
Language models (LMs) tend to memorize portions of their training data and emit verbatim spans. When the underlying sources are sensitive or copyright-protected, such reproduction raises issues of consent and compensation for creators and compliance risks for developers. We propose Anchored Decoding, a plug-and-play inference-time method for suppressing verbatim copying: it enables decoding from any risky LM trained on mixed-license data by keeping generation in bounded proximity to a permissively trained safe LM. Anchored Decoding adaptively allocates a user-chosen information budget over the generation trajectory and enforces per-step constraints that yield a sequence-level guarantee, enabling a tunable risk-utility trade-off. To make Anchored Decoding practically useful, we introduce a new permissively trained safe model (TinyComma 1.8B), as well as AnchoredByte Decoding, a byte-level variant of our method that enables cross-vocabulary fusion via the ByteSampler framework (Hayase et al., 2025). Across six model pairs on long-form metrics for copying risk and utility, Anchored and AnchoredByte Decoding define a new Pareto frontier, preserving near-original fluency and factuality while closing up to 75% of the measurable copying gap between the risky baseline and a safe reference, at a modest inference overhead.
Frontier LLM companies have repeatedly assured courts and regulators that their models do not store copies of training data. They further rely on safety alignment strategies via RLHF, system prompts, and output filters to block verbatim regurgitation of copyrighted works, and have cited the efficacy of these measures in their legal defenses against copyright infringement claims. We show that finetuning bypasses these protections: by training models to expand plot summaries into full text, a task naturally suited for commercial writing assistants, we cause GPT-4o, Gemini-2.5-Pro, and DeepSeek-V3.1 to reproduce up to 85-90% of held-out copyrighted books, with single verbatim spans exceeding 460 words, using only semantic descriptions as prompts and no actual book text. This extraction generalizes across authors: finetuning exclusively on Haruki Murakami's novels unlocks verbatim recall of copyrighted books from over 30 unrelated authors. The effect is not specific to any training author or corpus: random author pairs and public-domain finetuning data produce comparable extraction, while finetuning on synthetic text yields near-zero extraction, indicating that finetuning on individual authors' works reactivates latent memorization from pretraining. Three models from different providers memorize the same books in the same regions (r≥0.90), pointing to an industry-wide vulnerability. Our findings offer compelling evidence that model weights store copies of copyrighted works and that the security failures that manifest after finetuning on individual authors' works undermine a key premise of recent fair use rulings, where courts have conditioned favorable outcomes on the adequacy of measures preventing reproduction of protected expression.
Xinyue Liu, Niloofar Mireshghallah, Jane C. Ginsburg +1
Large language models (LLM) trained on web-scale corpora generate output that may infringe copyright, yet existing technical safeguards focus narrowly on verbatim memorisation. EU copyright doctrine applies a broader standards: substantial similarity, which extends to stylistic choices, narrative structure, and creative elaboration. This mismatch between what current methods detect and what the law protects leaves a significant compliance gap. We introduce PSALM, an LLM-as-a-judge framework that operationalises EU copyright doctrine through ten evaluators assessing computational overlap, stylistic dimensions (writing style, narrative voice), content dimensions (character, plot, scene, world building), and statutory exceptions (parody, pastiche, quotation, scènes à faire). Applying PSALM to Llama~3.2 models fine-tuned on translated historical Dutch literary works, we find that: 1) instruction-tuned models exhibit non-trivial baseline stylistic similarity prior to corpus exposure; 2) fine-tuning induces systematic stylistic appropriation across all infringement-relevant dimensions, extending beyond verbatim memorisation to abstract narrative patterns; 3) Negative Preference Optimisation unlearning substantially reduces similarity but leaves detectable residual stylistic patterns. These findings indicate that safeguards targeting literal copying alone are insufficient to mitigate broader copyright risks. PSALM provides infrastructure for auditable, legally informed compliance evaluation, though the relationship between automated similarity scores and infringement determinations requires validation by legal experts. This work bridges qualitative legal standards and quantitative technical measurement, exposing fundamental tensions between generative AI and EU intellectual property law.