I. ABSTRACT
The rise of Artificial Intelligence (AI) and its rapid advancements have transformed many aspects of our lives, impacting how content is created and disseminated. However, the rise of AI challenges the established concepts of authorship and prompts intriguing debates on whether content generated by non-human entities is eligible for copyright protection. The complexity further deepens when determining the rightful owner of such AI-generated work: is it the AI itself, the user, the programmer, the AI Company owner or does the work belong in the public domain? This article suggests “Hybrid Ownership” model by Atif Aziz as a potential solution to this conundrum. It explores the legal, ethical, and practical challenges surrounding AI-generated content. It examines the current copyright status of AI-generated content, explores the international legal frameworks, and evaluates its copyright ownership dilemmas. It emphasises the need for regulation and offers policy recommendations to strike a balance between promoting innovation in AI technology and safeguarding intellectual property rights.
II. THE ADVENT OF ARTIFICIAL INTELLIGENCE
Decades ago, the expression “Artificial Intelligence” or AI was used by John McCarthy in the year 1955 and it became popular when experts in science and mathematics gathered on the Dartmouth College Campus to launch the very first discussion on Artificial Intelligence in the year 1965.[ii] AI refers to “simulations of human intelligence in machines that are programmed to think like humans and mimic their actions.”[iii] It also refers to any machine which can perform functions associated with our human mind like intellectual labour comprising of abilities to learn, solve problems and rationalise. AI is emerging as a prevailing technological influence and some experts are even labelling it as the Fourth Industrial Revolution.[iv]
The realm of AI encompasses diverse branches like Machine Learning, Deep Learning, etc. each of which is significantly contributing to fields like science, art, medicine, literature and law. AI can now generate content ranging from essays to website codes. Moreover, in fields like music and literature, AI can autonomously make decisions in their output by replication human thinking and imagination. A compelling example of this capability is the artwork titled “Edmond de Belamy, from La Famille de Belamy” (“Edmond de Belamy”), which is “the first painting created by AI,” which commanded a remarkable $432,500 at auction in 2018.[v]
Some other examples include- Google ramping up support for artificial intelligence programming designed to create local news stories.[vi] Furthermore, there's the release of “The Next Rembrandt” by a team of researchers and museums in the Netherlands in 2016. It's a computer-generated artwork that analysed thousands of works by the famous 17th-century Dutch artist, Rembrandt.[vii] Additionally, Google's umbrella AI company, “DeepMind,” has successfully developed software capable of composing music by learning from recordings.[viii] These new industries extend beyond literature and art, with computers now able to write poetry, edit photographs, and even compose musicals.[ix]
III. THE AI AND COPYRIGHT CONUNDRUM
Copyright law, which has been built on the idea of granting exclusive rights to creators, has traditionally been tailored for works authored by humans. However, the rise of AI challenges the established concepts of authorship and prompts intriguing debates on whether content generated by non-human entities is eligible for copyright protection. Therefore, the absence of a human creator in the realm of AI-generated content blurs the lines between author and machine, posing a challenge to the applicability of copyright law to this novel form of creation.[x] Moreover, even if AI qualifies for copyright protection, the complexity arises when it comes to determining the rightful owner of the AI-produced work. Potential owners may include the AI itself, the AI programmer, the user, the AI company owner, or even the notion that the work belongs in the public domain with no specific owner. As a result, the protection and ownership of AI-generated work present intricate questions for both intellectual property enthusiasts and legal experts.[xi]
Dealing with AI-generated content brings forth a maze of challenges, particularly in the realms of fair use, creativity attribution and ethical considerations. The intersection of “Fair Use” and transformative works with AI-generated content introduces complexities in delineating boundaries, as AI systems can replicate existing copyrighted works, blurring the lines between transformative and derivative creations.[xii] Another point of contention lies in the application of the “Sweat of the Brow” doctrine[xiii] to AI-generated content, where the efficiency of AI algorithms challenges the traditional notion of labour-intensive creation. Furthermore, the widespread creation of AI-generated content raises ethical concerns due to potential unintended biases and discriminatory practices, as AI algorithms may learn and perpetuate existing societal biases present in training data. Analysing these legal and ethical issues reveals challenges for copyright law, and finding avenues to address them will allow us to encourage innovation while protecting creators’ rights.[xiv]
IV. COPYRIGHTABILITY OF AI-GENERATED CONTENT
Legal systems across jurisdictions have grappled with the question of whether AI-generated content is eligible for copyright protection.[xv] In the past, a widely held belief centred around the idea that, as a man-made invention, a computer was inherently a tool guided by human creators, thereby attributing authorship to humans. However, recent advancements in AI challenge this traditional perspective. Unlike earlier iterations, contemporary AI systems possess the capability to autonomously make decisions in the creative process, often without direct human intervention.[xvi] The theoretical scenario where AI-generated works could be deemed devoid of copyright, given their non-human authorship, raises concerns for industries reliant on such works. A critical consideration arises concerning the potential chilling effect on investments in automated systems.[xvii] This uncertainty could impact the future trajectory of innovation and technological advancements in the AI domain.[xviii]
Legal precedents offer significant insights into the copyrightability of AI-generated content, with a noteworthy example being the “Monkey Selfie” case.[xix] In this widely-known case, UK Wildlife photographer David Slater, intentionally left his camera for the curious macaque monkeys in Indonesia to explore. One inquisitive monkey named Naruto grabbed the camera and took “selfies.” Slater subsequently printed and published the pictures. In 2015, the animal rights group PETA sued Slater for copyright infringement while advocating on behalf of Naruto. The court's decision reiterated the traditional stance that animals, being non-human entities, cannot be granted copyright.[xx] However, such precedents have limitations in their applicability to AI-generated content, given the higher degree of sophistication and autonomy possessed by AI systems compared to animals.[xxi]
In the case Thaler v. Perlmutter[xxii] before the United States District Court for the District of Columbia, Stephen Thaler, the developer of an artificial intelligence program called the “Creativity Machine,” sought copyright registration for a visual artwork produced solely by this AI system. Despite identifying the AI as the creator and himself as the copyright owner in his application to register, the Copyright Office rejected Thaler’s application, citing copyright law’s requirement for human authorship. Thaler contested this decision through legal action, but the court upheld the Copyright Office's denial, emphasising the necessity of human involvement in copyright claims, ultimately affirming that autonomous works generated by AI systems do not qualify for copyright protection under current law.[xxiii]
International perspectives further muddle the waters, with varied approaches among different nations. Some countries have recognized AI in unique ways— Sophia, a remarkable robot, gained citizenship in Saudi Arabia,[xxiv] while DABUS is recognized as an inventor in South Africa and Australia.[xxv] Canada and India, under their respective copyright laws, have acknowledged RAGHAV, an AI, as a joint author. This development came when the copyright office acknowledged RAGHAV as a co-author alongside Ankit Sahni, an IP lawyer and the other co-author for the painting named ‘Suryast’.[xxvi] However, the US Copyright Office denied providing copyright registration for the artwork ‘Suryast’ citing the “lack of human authorship” which is a necessary factor supporting a copyright claim.[xxvii]
In a recent ruling on November 27, 2023, the Beijing Internet Court (BIC) addressed an infringement lawsuit (Li v. Liu[xxviii]), establishing that an AI-generated image is eligible for copyright protection under Chinese law. The court recognized the person who prompted the AI-generated image as the rightful author, emphasizing the “originality” and human-like “intellectual investment” involved in its creation. This case differs from Thaler v. Perlmutter[xxix] as Thaler sought to recognize the AI itself as the author, while in the Beijing case, the focus was on the person using the AI as a tool.[xxx]
The European Union is also contemplating granting AI the status of an electronic person.[xxxi] However, the lack of a global consensus is evident in each government's unique approach, showcasing no worldwide agreement on the protection of AI-generated works. WIPO (World Intellectual Property Organization) initiated discussions on IP and AI in 2019, 2020, 2022 and 2023 addressing crucial questions about the protection, legal personality, ownership, and potential sui generis protection for AI-created works.[xxxii] Despite these conversations, nations face challenges in devising a unified strategy for copyright protection for AI-generated content.
V. THE INTERNATIONAL LEGAL FRAMEWORK
Granting copyright to works generated by AI is not expressly prohibited.[xxxiii] However, indications suggest that many countries’ laws aren’t conducive to “non-human copyright.” The US Copyright Office insists on “registering works created by humans”, relying on cases like Feist Publications v. Rural Telephone Service[xxxiv], which emphasizes protecting “the fruits of labour that are founded in the creative powers of the human mind.” Similarly, the Acohs case[xxxv] in Australia declared that “computer-generated” works lack copyright protection as they aren't produced by humans. The CJEU echoes this sentiment, asserting in the Infopaq decision[xxxvi] that copyright can only be granted to original works which reflect the “author's intellectual creation”, which emphasized that human authorship is necessary for copyright existence.
Essentially, there are two approaches adopted by various countries regarding authorship. Several nations like India, Ireland, Hong Kong, the UK, and New Zealand opt for the first approach of attributing authorship to the programmer, a perspective which is also encapsulated in the Copyright, Designs and Patents Act of the UK.[xxxvii] However, certain jurisdictions like Ireland, New Zealand, and the United Kingdom, opt for the second approach by providing special provisions for ownership of “computer-generated” works.[xxxviii] For instance, the Copyright Act of UAE does not mandate that the content should be “authored by humans” for granting copyright protection.[xxxix]
The Berne Convention[xl], established in 1887, does not explicitly define who is an “author” and does not expressly prevent non-human entities from granting copyright protection. The Berne Convention’s guide clarifies the absence of a precise definition is due to varying interpretations across jurisdictions. In most jurisdictions with applicable copyright laws, legal entities are considered owners of copyright, while some recognise only “natural persons as authors.”[xli] Furthermore, the TRIPs agreement[xlii], which governs copyright standards globally, neither explicitly sanctions nor forbids non-human or artificial entities as authors.[xliii] Within the European Union, most member states lack explicit laws addressing AI-generated work, although some, like Germany and France, presently emphasize only natural persons as authors.[xliv] Therefore, the concept of authorship beyond natural persons remains evolving, while some international conventions make room for non-humans, it is still a bit unclear and needs more defining.
VI. COPYRIGHT OWNERSHIP OF AI-GENERATED CONTENT
Now, even if we “assume” international consensus on the copyrightability of AI-generated content, nonetheless, the question that persists is, who is the rightful owner of this copyright? Various scholarly articles and books discuss several options to understand the copyright ownership of AI-generated content.[xlv] From these discussions, five predominant and obvious options emerge: First, the AI system itself emerges as a contender, asserting autonomous ownership of the generated content. Second, the programmers argue for their stake, emphasizing their role in crafting the AI system. Third, the users, the driving force behind AI interactions, also stake a claim. Fourth, the companies which give birth to these AI entities also demand a claim. Fifth, a radical notion exists that AI-generated content seamlessly dwells in the public domain.
However, propelling the discourse into uncharted territory, Atif Aziz, in his research article for the European Journal of Artificial Intelligence and Machine Learning,[xlvi] goes a step further. It gives a sixth option: Hybrid Ownership. This innovative approach advocates for the establishment of what Aziz calls an “Artificial Intelligence Legal Entity (AiLE)”, which embodies the AI system, its programmers, users, and the owning company, all under the legal umbrella of an artificial personality. According to Aziz, the hybrid ownership model emerges as a solution that leverages strengths while mitigating the shortcomings of traditional options.
This approach safeguards the author's rights to the original work effectively, attributing it to its rightful stakeholders. It addresses concerns related to rewards, incentives, and ongoing accountability, ensuring the proper attribution of copyrightable work. By offering a legal personality to stakeholders under the “Artificial Intelligence Legal Entity (AiLE)”, including users, companies, programmers, and the AI system itself, the hybrid option establishes a unique framework. The stakeholders' contributions can be recognized through a Stakeholders Agreement by complying with international copyright laws that allow artificial entities to own original works. This paves the way for legislative reforms in jurisdictions still bound to human ownership paradigms.[xlvii]
Moreover, the hybrid model tackles issues of liability and accountability and provides a legal identity to address retribution if there is copyright infringement. Ownership assignment to AiLE ensures accountability during various stages of AI production. Crucially, this collective entity offers an equitable monetization mechanism for AI-produced work, minimizing the risk of corporate monopolies. Recognizing the involvement of artists, writers, and musicians in the AI system's training process, the hybrid model ensures a fair distribution of benefits.[xlviii] By providing legal personality to users, programmers, AI systems and companies, the hybrid model addresses the modern-day dilemma of copyright ownership for AI-produced original works. This groundbreaking concept by Aziz, offers a compelling and forward-thinking solution for the evolving intersection of AI and copyright law.
While there aren't specific real-life case studies of AiLEs in practice yet, there are examples of similar legal entities or structures that involve multiple stakeholders and artificial entities. One such example is “creative collaboration”[xlix] or “joint ownership”[l]. In creative industries such as music and film, collaborations between artists, producers, and other stakeholders are common. They enter into Collaboration Agreements, which result in jointly owned copyrights, where all parties involved have a stake in the work’s ownership and revenue. Similarly, users, companies, programmers, and the AI system itself can enter into a Stakeholder Agreement, where all the involved parties can hold a share in both the ownership and revenue of the work.
VII. NEED FOR REGULATION AND WAY FORWARD
Certain legal precedents suggest that addressing the copyright dilemma on a case-to-case basis might be a viable approach. A notable case in this regard is Nova Productions v Mazooma Games,[li] where the Court of Appeal grappled with determining the authorship of a computer game. The court's ruling emphasized that a player's input lacked an artistic nature and did not involve artistic skill or labour. This prompts the consideration of evaluating user actions individually as a potential solution.[lii] However, the surge in AI's role in rapidly generating literature, art, and music raises questions about the practicality of implementing a case-by-case approach in these evolving creative landscapes.
The above discussion highlights the pressing need for reform in addressing the convergence of AI and copyright law. Key organisations such as the WIPO,[liii] the European Patent Office (EPO),[liv] the United States Patent and Trademark Office (USPTO),[lv] and the African Regional Intellectual Property Organization (ARIPO)[lvi] have facilitated dialogues among stakeholders, scholars, and experts. The focus lies on reviewing policies related to AI and intellectual property and the consensus is that concrete policy actions are essential to harmonize IPRs and AI technologies. The path forward involves international treaty modifications, directives at multilateral and regional levels, and national reforms to accommodate AI in IP frameworks.
Addressing the complexities of fair use and transformative works is crucial when it comes to AI-generated content. Finding a balance between protecting copyright holders and harnessing the transformative potential of AI systems is essential. Policymakers should consider crafting clear guidelines that clarify the boundaries of fair use in AI-generated content, considering factors such as the purpose of use, the nature of the copyrighted work, the amount used, and potential market impact. Establishing such guidelines can foster innovation, creativity, and AI technology development while also safeguarding the interests of copyright holders.[lvii]
Navigating AI-generated content complexities requires education for professionals in legal, ethical, and technical aspects, public awareness campaigns for dispelling AI myths, building trust and empowering stakeholders to engage responsibly. Given AI's borderless nature, global cooperation is essential to ensure consistent legal frameworks. This cooperation fosters knowledge exchange, best practices sharing, and unified copyright standards. Legal reforms are essential, requiring collaboration between legislators, tech experts, and creative professionals to establish adaptive frameworks that balance innovation, protect creators' rights, and address ethical concerns.[lviii]
VIII. CONCLUSION
It is imperative to update or reform copyright laws to embrace the distinctive features of AI-generated content. Revisions should bring clarity to aspects like authorship, ownership, and infringement in the realm of AI-generated works. This may entail expanding the notion of authorship to encompass both human creators and AI algorithms or creating a new set of rights tailored specifically for AI-generated content. It may also entail, creating a mechanism for hybrid ownership or Artificial Intelligence Legal Entity (AiLE), which embodies the AI system, its programmers, users, and the owning company, all under the legal umbrella of an artificial personality. By ensuring that copyright laws stay relevant and adaptable, policymakers can establish a clear legal framework that nurtures creativity and safeguards the rights of all stakeholders.
The interpretive challenges and legal complexities surrounding the classification of AI-generated content as “fair use” or “transformative works”, can be addressed by crafting guidelines on “fair use” in this context, considering factors like purpose, nature of the work, amount used, and potential market impact. These measures aim to encourage innovation and creativity in AI technologies while respecting the interests of copyright holders. Moreover, harmonizing international legal frameworks about AI-generated content can create unified standards while enhancing legal certainty, promoting global innovation, and preventing cross-border inconsistencies that may hinder the development and distribution of AI-generated content.
[i] The author is a student at Maharashtra National Law University, Nagpur
[ii]“Tombekai, Tom, The Ownership of Artificial Intelligence (AI) Generated & Created Inventions, Social Science Research Network, (July 05, 2020), https://doi.org/10.2139/ssrn.3772947.
[iii] Jake Frankenfield, Artificial Intelligence (AI): What It Is and How It Is Used. Investopedia, (Dec. 04, 2023), https://www.investopedia.com/terms/a/artificial-intelligence-ai.asp.
[iv] Christopher Health et al, Intellectual Property Law and the Fourth Industrial Revolution, Kluwer Law International, 2020.
[v] Aziz, Atif. Artificial Intelligence Produced Original Work: A New Approach to Copyright Protection and Ownership. European Journal of Artificial Intelligence and Machine Learning, vol. 2, no. 2, Mar. 2023, pp. 9–16. www.ej-ai.org, https://doi.org/10.24018/ejai.2023.2.2.15.
[vi]“Gregory, Julia, Press Association Wins Google Grant to Run News Service Written by Computers, The Guardian, 6 July 2017, The Guardian, https://www.theguardian.com/technology/2017/jul/06/press-association-wins-google-grant-to-run-news-service-written-by-computers.
[vii] Brown, Mark. ‘New Rembrandt’ to Be Unveiled in Amsterdam. The Guardian, 5 Apr. 2016. The Guardian, https://www.theguardian.com/artanddesign/2016/apr/05/new-rembrandt-to-be-unveiled-in-amsterdam.
[viii] Coldewey, Devin. Google’s WaveNet Uses Neural Nets to Generate Eerily Convincing Speech and Music. TechCrunch, 9 Sept. 2016, https://techcrunch.com/2016/09/09/googles-wavenet-uses-neural-nets-to-generate-eerily-convincing-speech-and-music/.
[ix] Andres Guadamuz, Artificial Intelligence and Copyright, World Intellectual Property Organisation (WIPO) Magazine, Oct. 2017, https://www.wipo.int/wipo_magazine/en/2017/05/article_0003.html.
[x] Abdikhakimov, Islombek, Unraveling the Copyright Conundrum: Exploring AI-Generated Content and Its Implications for Intellectual Property Rights, International Conference on Legal Sciences, vol. 1, no. 5, June 2023, pp. 18–32. science-zone.org, https://science-zone.org/index.php/conference/article/view/42.
[xi] Supra Note 4.”
[xii] Supra Note 9.
[xiii] Saksena, Hailshree, Doctrine of Sweat of the Brow, Social Science Research Network, 03 May 2009, https://ssrn.com/abstract=1398303.
[xiv]“Hristov, Kalin, Artificial Intelligence and the Copyright Dilemma, 1 Sept. 2016, Social Science Research Network, https://papers.ssrn.com/abstract=2976428.
[xv] Supra Note 9.
[xvi] Bracha, Oren, The Work of Copyright in the Age of Machine Production, 24 Sept. 2023, Social Science Research Network, https://doi.org/10.2139/ssrn.4581738.
[xvii] Supra Note 8.
[xviii] Naqvi, Zach, Artificial Intelligence, Copyright, and Copyright Infringement, Marquette Intellectual Property Law Review, vol. 24, no. 1, Jan. 2020, p. 16, https://scholarship.law.marquette.edu/iplr/vol24/iss1/4.
[xix] Naruto v. Slater, 888 F.3d 418 (9th Cir. 2018).”
[xx]“Nguyen, Phuoc, The Monkey Selfie, Artificial Intelligence and Authorship in Copyright: The Limits of Human Rights, 2019, Public Interest Law Journal New Zealand, vol. 6 p. 121, http://www.nzlii.org/nz/journals/NZPubIntLawJl/2019/7.html.
[xxi] Supra Note 9.
[xxii] Thaler v. Perlmutter, Civil Action No. 22-CV-384-1564-BAH, https://www.wipo.int/wipolex/en/judgments/details/1840.
[xxiii] Atreya Mathur, Case Review: Thaler v. Perlmutter (2023), Center for Art Law, 11 Dec. 2023, https://itsartlaw.org/2023/12/11/case-summary-and-review-thaler-v-perlmutter/.
[xxiv] Jr, Cleve R. Wootson, Saudi Arabia, Which Denies Women Equal Rights, Makes a Robot a Citizen, Washington Post, 5 Dec. 2021. www.washingtonpost.com, https://www.washingtonpost.com/news/innovations/wp/2017/10/29/saudi-arabia-which-denies-women-equal-rights-makes-a-robot-a-citizen/.
[xxv] Oriakhogba, Desmond, Dabus Gains Territory in South Africa, and Australia: Revisiting the AI-Inventorship Question, 1 Oct. 2021, Social Science Research Network, https://doi.org/10.2139/ssrn.3998162.
[xxvi] Chawla, Vedika, Ankit Sahni’s AI ‘Co-Authored’ Artwork Denied Registration by US, Continues to Be Registered in India, SpicyIP, 15 Dec. 2023, https://spicyip.com/2023/12/ankit-sahnis-ai-co-authored-artwork-denied-registration-by-us-continues-to-be-registered-in-india.html.
[xxvii] US Copyright Office Review Board, 11 Dec 2023, https://www.copyright.gov/rulings-filings/review-board/docs/SURYAST.pdf
[xxviii] Li v. Liu (2023) Jing 0491 Min Chu No. 11279, http://www.lawinfochina.com/display.aspx?id=8655&lib=case
[xxix] Supra Note 21.
[xxx] Wininger Aaron, Beijing Internet Court Recognizes Copyright in AI-Generated Images, The National Law Review, Vol. 14, No. 85, March 25, 2024, https://www.natlawreview.com/article/beijing-internet-court-recognizes-copyright-ai-generated-images
[xxxi] Nowik, Paweł, Electronic Personhood for Artificial Intelligence in the Workplace, Computer Law & Security Review, vol. 42, Sept. 2021, p. 105584, ScienceDirect, https://doi.org/10.1016/j.clsr.2021.105584.
[xxxii] Artificial Intelligence and Intellectual Property Policy, WIPO, https://www.wipo.int/about-ip/en/artificial_intelligence/conversation.html.
[xxxiii] Supra Note 8.”
[xxxiv]“Feist Publications, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340 (1991)
[xxxv] Acohs Pty Ltd v Ucorp Pty Ltd [2012] FCAFC 16 (2 March 2012)
[xxxvi] Infopaq International A/S v. Danske Dagblades Forening, C-5/08
[xxxvii] Supra Note 8.
[xxxviii] Palace, Victor, What If Artificial Intelligence Wrote This? Artificial Intelligence and Copyright Law, Florida Law Review, vol. 71, no. 1, Nov. 2020, p. 217, https://scholarship.law.ufl.edu/flr/vol71/iss1/5.
[xxxix] Al-Sharieh, Saleh, The Intellectual Property Road to the Knowledge Economy: Remarks on the Readiness of the UAE Copyright Act to Drive AI Innovation, Law, Innovation and Technology, vol. 13, no. 1, 2021, pp. 141–66. United Arab Emirates University, https://doi.org/10.1080/17579961.2021.1898312.
[xl] Berne Convention for the Protection of Literary and Artistic Works, Sept. 9, 1886, as revised at Paris on July 24, 1971 and amended in 1979, https://treaties.un.org/Pages/showDetails.aspx?objid=0800000280115ec9.
[xli] Id
[xlii] Declaration on the TRIPS Agreement and Public Health, Nov. 14, 2001, https://www.wto.org/english/docs_e/legal_e/27-trips_01_e.htm.
[xliii] Veronica Aina, Copyright Law, and Artificial Intelligence: A Critique of the Emerging Legal Framework in Nigeria, Mauritius: Lambert; 2020.”
[xliv] Id
[xlv] Supra Note 29.
[xlvi]“Aziz, Atif, Artificial Intelligence Produced Original Work: A New Approach to Copyright Protection and Ownership, European Journal of Artificial Intelligence and Machine Learning, vol. 2, no. 2, Mar. 2023, pp. 9–16. www.ej-ai.org, https://doi.org/10.24018/ejai.2023.2.2.15.
[xlvii] Id.
[xlviii] Id.
[xlix] Susan Ford, Creative Collaboration and Copyright, 19 March 2020, https://www.linkedin.com/pulse/creative-collaboration-copyright-susan-ford/
[l] Malhan, Priyanka, Joint Ownership of Intellectual Property: Is it a Profit or Loss, Indian Journal of Economics and Business, Vol. 19, No. 1, 2020, https://www.ashwinanokha.com/resources/ijeb%20v19-1-1-Priyanka%20Malhan.pdf.
[li]“Nova Productions v. Mazooma Games [2007] EWCA Civ 219.
[lii] Artificial Intelligence and Copyright, WIPO Magazine, 2017, https://www.wipo.int/wipo_magazine/en/2017/05/article_0003.html.
[liii]“Artificial Intelligence and Intellectual Property Policy, WIPO, https://www.wipo.int/about-ip/en/artificial_intelligence/policy_exhibition.html.
[liv] Artificial Intelligence, Epo.Org, https://www.epo.org/en/news-events/in-focus/ict/artificial-intelligence.
[lv] USPTO Releases Report on Artificial Intelligence and Intellectual Property Policy. 6 Oct. 2020, https://www.uspto.gov/about-us/news-updates/uspto-releases-report-artificial-intelligence-and-intellectual-property.
[lvi] The African Regional Intellectual Property Organization (ARIPO), Effects of Artificial Intelligence (AI) and Blockchain Technology on the Management of Copyright and Related Rights, https://www.aripo.org.”
[lvii] Supra Note 9.
[lviii] Id.
コメント