Plaintiffs Advance Local Media LLC; Advance Magazine Publishers Inc. d/b/a Condé Nast; The Atlantic Monthly Group LLC; Forbes Media LLC; Guardian News & Media Limited; Insider, Inc.; Los Angeles Times Communications LLC; The McClatchy Company, LLC; Newsday, LLC; Plain Dealer Publishing Co.; Politico LLC; The Republican Company; Toronto
Star Newspapers Limited; and Vox Media, LLC (collectively “Publishers”), by their attorneys, Oppenheim + Zebrak, LLP, for their complaint against Defendant Cohere Inc. (“Cohere”), allege on personal knowledge as to matters relating to themselves and on information and belief as to all other matters, as set forth below.