text: What this means for our purposes is that even if one acquires a digital book from, for 
  example, Amazon, and it is lawful under copyright law to use that book in AI training, it can 
  still generally be unlawful to circumvent the DRM to do so, outside narrow exceptions. 
   25 
  Thus, the ability to use in-copyright books encumbered by DRM — that is, most all books sold 
  by major publishers — is generally limited.   26 
  
  Practically, using in-copyright books to build a books commons for AI training — while relying 
  on copyright’s limitations and exceptions — requires turning a physical book into digital form, 
  or otherwise engaging in the laborious process of manually re-creating a book’s text (i.e., re- 
  typing the full text of the book) without circumventing the technical restrictions themselves. 