Several points remain open. Whether the Virginia court will treat the 2020 fee default as ending the license is undecided, and no ruling has issued. The Third Circuit's reasoning is partly sealed, and the public judgment is brief, so its full scope is not yet clear. The Ross case also does not involve a large language model or other generative AI tool, which limits how far the holding reaches into current AI products.
The Clio filing arrives weeks after the appellate decision, which gives licensing of legal data new weight. The Third Circuit recognized harm both to Westlaw's existing legal-research market and to an emerging market for licensing headnotes as AI training data. Attorneys advising on data licensing should check termination and renewal terms in existing feed agreements, especially any that depend on payment status. They should also track whether the Virginia court treats a lapsed license as a contract end or as something revivable, since that answer will shape how courts handle AI training-data deals.