The designation of ChatGPT as a VLOSE represents a groundbreaking regulatory precedent for artificial intelligence. While traditionally viewed as a conversational agent, the Commission recognizes ChatGPT as a hybrid service. Because the system actively engages with and responds to users’ prompts and queries, including by searching the live web to retrieve and synthesize information, it functionally operates as an online search engine under the DSA. This classification ensures that generative AI models with retrieval capabilities cannot evade accountability by framing themselves merely as “chatbots” rather than powerful information gatekeepers.