What happens in these content cases is they get settled almost every single time. So the case law doesn't get codified, they just get settled out of court. If you go look at all the fair use cases, they almost never go to the mat. And so this one will just be settled.
Available reporting through late 2025 shows no evidence that the Scarlett Johansson–OpenAI "Sky" voice dispute ever became a filed lawsuit or ended in an out‑of‑court settlement.
Instead, Johansson hired legal counsel, sent two letters to Sam Altman and OpenAI demanding details on how the Sky voice was created, and OpenAI then "reluctantly agreed" to take down the Sky voice and apologized publicly. News coverage at the time and since describes this sequence—letters followed by OpenAI pausing/removing the voice—but does not report any settlement agreement.(fortune.com) Legal and policy analyses from TechTimes and the American Bar Association in late 2024 explicitly note that Johansson had not filed a lawsuit and speak only in hypothetical terms about what would happen "if the actress decides to sue OpenAI."(techtimes.com) A Georgetown Law explainer likewise frames the dispute as a potential right‑of‑publicity case, not as an existing one.(georgetown.edu)
Later 2025 profiles and interviews describe Johansson as having taken "legal action" in the sense of threatening action and pushing for legislation, and they emphasize that OpenAI dropped the Sky voice following this pressure, but they still do not mention any lawsuit or settlement being reached.(instyle.com) Nor is there any reported court decision involving Johansson and OpenAI, let alone one that changes U.S. fair‑use precedent; experts consistently describe the main theory here as right of publicity rather than copyright fair use.(americanbar.org)
So while it is true that no new fair‑use case law emerged from this incident, the central part of the prediction—that this specific Johansson vs. OpenAI dispute would be resolved via an out‑of‑court settlement after a case was brought—did not occur. The controversy effectively cooled after OpenAI withdrew the Sky voice under legal threat, with no lawsuit filed and no settlement reported, making the prediction wrong overall.