Summary: This article examines the Delhi High Court’s judgement in ANI v. Open AI as more than a copyright ruling, arguing that its reasoning on what constitutes “research” offers a persuasive analytical framework for one of the central uncertainties under the DPDPA: whether commercial AI model training can qualify for the Act’s research exemption. It contends that the Court’s purpose, fairness and public interest test, while developed under Section 52(1)(a) of the Copyright Act, translates naturally to Section 17(2)(b) of the DPDPA, and removes a significant conceptual obstacle to treating AI training as research under data protection law. It will be relevant to readers tracking the evolving Indian jurisprudence on AI and its intersection with copyright and data protection law.