I'm using "words" as an informal summary of the large legal concept of what can be copyrighted, and "facts/concepts/ideas" for what cannot be. So it's not quite

I'm using "words" as an informal summary of the large legal concept of what can be copyrighted, and "facts/concepts/ideas" for what cannot be. So it's not quite a fair use argument (which someone uses the words for certain protected purposes like parody), and I do not think OpenAI is making a fair use argument (although I'd welcome links to the contrary). In other words, it has nothing to do with your or anyone else's interpretation of what the CC license claims to protect ("an arrangement or transformation"), and only relies on what rights they are legally allowed to assert.