Midjourney has asked a federal court to overturn a judge's ruling that allowed Disney, Warner Bros. Discovery, and Universal Studios to keep most of their internal AI operations secret during copyright litigation. The decision could affect how discovery works in AI copyright cases across the industry.

The image-generation company filed its Motion to Compel on March 27, 2026, targeting the three studios that sued it. Disney and Universal filed first on June 11, 2025, claiming Midjourney generated unauthorized images of their copyrighted characters. Warner Bros. Discovery followed in September 2025 with similar allegations involving Superman and Scooby-Doo. Midjourney now wants access to the studios' AI business plans, training datasets, model architecture files (called weights), research reports, and board presentations about their AI strategy.

In June 2026, Magistrate Judge Joel Richlin ruled against Midjourney, saying the studios only had to disclose materials related to products they sell to customers. Midjourney is now asking the district court to reverse that decision.

The "Unclean Hands" Strategy

Midjourney's legal argument centers on a simple premise: if the studios are themselves training AI systems on copyrighted material, that undercuts the moral and legal weight of their infringement claims. Bobby Ghajar, Midjourney's attorney, stated the theory plainly in the filing, as Engadget reported: "If Plaintiffs are doing the very thing they seek to punish, that evidence goes to the heart of Midjourney's fair use and unclean hands defenses."

The "unclean hands" doctrine works like this: if one party has engaged in wrongdoing related to the dispute itself, a court can refuse to help them win their case. Midjourney combines this with a fair use argument to create a two-part strategy. Under the first path, the studios' own AI training practices would show that training on publicly available works is an industry standard, strengthening Midjourney's fair use claim. Under the second, those same practices would show the studios are doing exactly what they accuse Midjourney of doing, which supports the unclean hands defense. Neither path requires Midjourney to prove it acted lawfully on the merits alone; together they complicate whether the studios have the right to sue at all.

Midjourney's core position — that training AI on publicly available images is a transformative use and therefore legal — remains one of the biggest unanswered questions in U.S. AI copyright law. The discovery request is, in part, an attempt to build factual evidence around how the studios themselves have answered that question internally.

What's at Stake

The scope of discovery allowed in AI copyright cases is still being defined. Judge Richlin's ruling drew a line at consumer products, treating internal research, model files, and strategy documents as outside the bounds of discovery. If the district court overturns that ruling, it would tell defendants in AI copyright cases they have much broader rights to examine plaintiffs' own AI practices, whether or not those practices are publicly known.

The studios have a legal argument for keeping that information private. Standard discovery rules require information to be relevant to the claims or defenses in the case, and a court could reasonably say that how Disney uses AI internally has nothing to do with whether Midjourney copied their characters. Midjourney's counter is that the studios' internal conduct is not incidentally relevant but directly central to the case — it speaks to whether training AI on copyrighted works is legally and practically accepted industry practice.

The broader context matters. Disney, Universal, and Warner Bros. Discovery also sued Chinese AI company MiniMax in September 2025, and that company lost its attempt to dismiss the case on May 26, 2026. The studios appear to be running a coordinated intellectual property strategy across multiple AI defendants. The question now before the court is whether they can pursue that strategy while keeping their own AI development hidden from scrutiny.

This ruling will likely set a precedent for how discovery works in future AI copyright cases, particularly those where the plaintiff is also developing AI systems. That covers a significant part of the industry. Courts in later cases will follow whatever reasoning the district court provides here, so the judge's written opinion, if issued, could matter as much as the decision itself.