This is Part II of a two-part piece critiquing the Delhi High Court’s reasoning in ANI Media Pvt Ltd v OpenAI OpCo LLC. Part I argued that the Court improperly severs “research” from private or personal use and that, in light of Chintamani Rao, Section 52 is not a provision that courts may enlarge through interpretation. This part begins by addressing a counterargument to the latter claim, namely that Chintamani Rao is distinguishable because the Court invoked the doctrine of updating construction to interpret “research” broadly, rather than adding a new category to Section 52. We argue that this application of updating construction was incorrect because the doctrine requires “genuine ambiguity” in the law, which was absent here. We then advance a third argument that, even assuming the Court was correct to interpret Section 52 expansively, its fairness inquiry was inadequate. In particular, we argue that the inquiry omits consideration of the amount and substantiality of the work taken and imports the transformative use doctrine from a different statutory limb without adequate reasoning.