| Keywords [eng] |
Artificial Intelligence (AI), AI-generated content, AI-assisted works, copyright law, human authorship, originality, creativity, ownership, intellectual property, moral rights, economic rights, European Union (EU), United States (US), comparative legal analysis, legal reform, sui generis rights, Berne Convention, DSM Directive, AI Act, US Copyright Office, Zarya of the Dawn, legal uncertainty, autonomous AI creation, authorship attribution, international copyright treaties. |
| Abstract [eng] |
This thesis compares and contrasts the US and EU in order to investigate if and how outputs produced by or employing artificial intelligence (AI) can be protected under copyright law. It tackles the conflicts that occur when AI-generated output is subjected to the traditional copyright principles of authorship, originality, and creativity.The study investigates:how AI-generated and AI-assisted works differ from one another.The US places more emphasis on economic rights and practical usage than the EU does on moral rights and authorial personality.Due to the lack of a human author, the existing legal position in both jurisdictions forbids copyright to fully autonomous AI outputs.Important legal precedents and decisions include the Zarya of the Dawn ruling from the US Copyright Office and EU laws like the AI Act and the DSM Directive.In both legal regimes, human authorship is still a fundamental prerequisite for copyright protection.If significant human creative input can be shown, AI-assisted works might be eligible for protection.Regarding who owns AI-generated works, if anyone, there is no clear consensus.Because autonomous AI production cannot be adequately addressed by current copyright frameworks, legal reform or the formation of sui generis rights is required.There is little guidance available on these changing challenges from international instruments such as the Berne Convention. |
