Actually, it’s because, as per Feist Publications, Inc. v. Rural Telephone Service Co., facts cannot be copyrighted.

This legal trick only works for rewriting an article reporting on a factual event—since the events are uncopyrightable facts, the only part of the article which can be copyrighted is the stylistic writing.

Let me quote from a recent legal opinion on AI summaries (The New York Times Company v. Microsoft Corporation et al 2025):

>>> Exhibit 11 to the CIR complaint provides website links to articles that CIR alleges were unlawfully abridged by defendants in their ChatGPT and Copilot outputs. (CIR, FAC Ex. 11.) Examining the similarities between those outputs and the corresponding CIR articles, including the “total concept and feel, theme . . . sequence, pace, and setting,” Williams v. Crichton, 84 F.3d 581, 588 (2d Cir. 1996), the Court concludes that the “abridgments” contained in Exhibit 11 are not substantially similar to CIR’s copyrighted works as a matter of law.

The alleged abridgments are detailed summaries, usually in bullet point form, of the facts contained in CIR’s articles. Those summaries—which differ in style, tone, length, and sentence structure from CIR’s articles—are not “substantially similar” to CIR’s copyrighted works. They present the “facts in a different arrangement”—bullet point lists or short summary paragraphs—“with a different sentence structure and different phrasing.” Nihon, 166 F.3d at 71. In short, the abridgments in Exhibit 11 are not substantially similar, qualitatively or quantitatively, to the original CIR articles as a matter of law. The Court therefore grants OpenAI’s motion to dismiss CIR’s claim of direct infringement under 17 U.S.C. § 501 insofar as it relates to the “abridgments” contained in Exhibit 11.<<<

But I meant, isn't saving articles for personal record a legitimate use of Fair Use? Do you really need to paraphrase them first?