I think it's an apt analogy, though I disagree about the implication.
If I use ChatGPT to create a work, and that work is "close enough" to an existing copyrighted work, then it seems like I am guilty of copyright violation, not ChatGPT.
It's not an analogy. This is actually what is done with ML. It is literally a best fit curve problem.
Or maybe it is actually an analogy, but then if this was the case the entire field of ML is capable of only understanding the intricacies of ML through the analogy of curve fitting and what's actually going on underneath the analogy remains elusive.
If I use ChatGPT to create a work, and that work is "close enough" to an existing copyrighted work, then it seems like I am guilty of copyright violation, not ChatGPT.