The complaint filed by Elon Musk against OpenAI and Sam Altman alleges that OpenAI breached its founding agreement, which was supposedly created to develop artificial general intelligence (AGI) for the benefit of humanity. The complaint claims that OpenAI's transition from a non-profit to a for-profit entity, its secrecy around GPT-3 and -4, and its alleged breach of a "Founding Agreement" are all evidence of this breach. Musk also alleges that Altman and OpenAI's board breached their fiduciary duty and engaged in unfair business practices. The complaint centers on the question of whether there is a valid contract between Musk and OpenAI, specifically regarding the existence of the alleged "Founding Agreement".