ChatGPT in Siri 'Persistently Underperforming,' Says OpenAI

Even if the Court assumes that Apple users who elect to use ChatGPT through Apple Intelligence are foreclosed from OpenAI's rivals (which they are not), the amount of foreclosure caused by the Agreement is indisputably de minimis.

While Plaintiffs' experts declined to calculate foreclosure shares, OpenAI's expert, Dr.

Catherine Tucker, calculated the share of GenAI consumers who accessed ChatGPT through Apple Intelligence across multiple metrics using the same data and market definition relied upon by Plaintiffs' experts. On these assumptions, Dr. Tucker found foreclosure shares of [REDACTED] across all metrics, consistent with OpenAI's internal view that Apple Intelligence saw minimal usage.