Home » Blog » Code, Creativity, and Couture: Intellectual Property Rights in AI-Generated Fashion Designs – A Comparative Analysis of India, the United Kingdom, and the United States

Code, Creativity, and Couture: Intellectual Property Rights in AI-Generated Fashion Designs – A Comparative Analysis of India, the United Kingdom, and the United States

Authored By: Hiba

Bharati Vidhyapeet New Law College

ABSTRACT

AI tools can now create fashion designs on their own, which creates a legal question: Who owns the design, the AI or the human using it?

This article compares the laws of India, the UK, and the US to find out how ownership and copyright are decided for AI-generated fashion designs.

The study finds that AI cannot legally be considered an author or owner of a design. Copyright protection is only possible when a human plays an important creative role.

  • India: The copyright belongs to the person who instructs or uses the AI to create the design.

  • UK: The copyright belongs to the person who makes the necessary arrangements for the AI to generate the design.

  • US: Copyright is given only to works created by humans. If a design is created entirely by AI without human creativity, it cannot receive copyright protection.

The article also points out that current laws are not fully prepared for modern AI technology. For example, some legal terms in India are outdated, and the UK law is unclear about how much human creativity is needed.

The article concludes that AI-generated fashion designs should be protected only when a human has made a meaningful creative contribution. It also recommends updating copyright laws so they can better deal with new AI technologies while protecting human creators.

Introduction

Imagine a fashion designer sitting with a cup of coffee, typing a simple prompt like “design a futuristic red evening gown inspired by space travel” into an AI tool. Within seconds, the screen fills with dozens of creative designs that might have taken hours or even days to sketch by hand. Sounds impressive, right? But it also raises an important question: if a machine helps create the design, who actually owns it?

Artificial Intelligence (AI) is rapidly changing the fashion industry. From generating fabric patterns and clothing sketches to creating virtual outfits for digital fashion shows, AI has become a powerful creative assistant. Fashion brands and designers are increasingly using these tools to save time, explore new ideas, and stay ahead in a highly competitive market.

However, the law has not always kept pace with technology. Copyright law was built around the idea that creative works are made by human beings.[1] When an AI system produces a fashion design, it becomes unclear who should be recognized as the author. Is it the designer who typed the prompt? The company that developed the AI software? Or can a design created largely by AI remain without copyright protection altogether?

These questions are no longer science fiction. As AI-generated content becomes more common, courts, governments, and legal experts around the world are trying to determine how existing intellectual property laws should apply. The answers are especially important in the fashion industry, where originality and creativity are valuable commercial assets.

This article examines how India, the United Kingdom (UK), and the United States (US) address the issue of authorship and ownership of AI-generated fashion designs. By analyzing copyright laws, policy documents, and important legal decisions, it explores who receives intellectual property rights when AI participates in the creative process. [2] It also highlights the challenges that AI presents to traditional copyright principles and evaluates whether current legal frameworks are equipped to handle the future of fashion in an increasingly AI-driven world

Background and Conceptual Framework

Fashion and intellectual property (IP) have always been closely connected. A unique textile print, fabric pattern, embroidery design, or artistic illustration on clothing is not just a fashion element but also a creative work that may be protected by law. [3]Copyright and design laws help designers safeguard their creations from unauthorized copying and ensure that they receive recognition and financial benefits for their originality.

The emergence of Artificial Intelligence (AI) has transformed the way fashion designs are created. Today, AI tools can generate clothing sketches, fabric prints, and even complete fashion collections within seconds based on simple user prompts. While this technology offers exciting opportunities for innovation and efficiency, it also raises an important legal question: who owns a fashion design created by AI? Is it the user who provided the prompt, the company that developed the AI system, or the AI itself?

Traditionally, copyright law has been based on the assumption that creative works originate from human authors. AI challenges this assumption because it can produce complex and visually appealing designs with minimal human involvement. As a result, legal systems around the world are struggling to determine how existing intellectual property laws should apply to AI-generated works.

Different countries have adopted different approaches to this issue. In India, Section 2(d)(vi) of the Copyright Act, 1957 states that the author of a computer-generated work is the person who “causes” the work to be created[4]. This means that the individual who initiates or directs the AI process is generally considered the author. Similarly, the United Kingdom’s Copyright, Designs and Patents Act 1988 provides that when a work is generated by a computer without a human author, the author is the person who made the necessary arrangements for its creation.[5] In both jurisdictions, the law focuses on the human involvement behind the AI-generated output.

The United States takes a stricter approach. U.S. copyright law requires human authorship and does not recognize copyright in works created entirely by AI[6]. According to the U.S. Copyright Office, only works containing meaningful human creative contribution can receive copyright protection.

Another key concept in this debate is originality. [7]Copyright protects only original works, meaning that some degree of human creativity, skill, or judgment must be present. When AI generates a design, determining the source of originality becomes difficult. This has led to ongoing debates about the extent of human involvement required for copyright protection.

Despite these differences, one principle remains common across jurisdictions: AI is regarded as a tool rather than a legal creator.[8] As AI becomes increasingly integrated into the fashion industry, lawmakers must balance technological innovation with the need to preserve and reward human creativity. This challenge lies at the center of the evolving relationship between AI, fashion, and intellectual property law.

Legal Analysis

India: “The Person Behind the Prompt Gets the Credit”

Imagine you ask an AI tool to create a luxury saree pattern inspired by Mughal art. The AI does all the drawing and generates a beautiful design within seconds. The obvious question is: Who owns the design?

Indian copyright law answers this through Section 2(d)(vi) of the Copyright Act, 1957. The provision states that for a computer-generated work, the author is “the person who causes the work to be created.” In simple terms, the law looks for the human who started or directed the creative process.

[9]At first glance, this seems straightforward. However, AI complicates matters because there are usually at least two humans involved: the developer who built the AI system and the user who entered the prompt. Both contributed to the final result, but in different ways. The law does not clearly explain whose contribution matters more.

The challenge is that this provision was introduced in 1995 long before modern AI tools such as ChatGPT, Midjourney, or DALL·E existed.[10] Lawmakers were thinking about ordinary computer-generated works, not machines capable of producing original-looking fashion collections in seconds. As a result, courts have not yet provided a definitive answer for AI-generated fashion designs.

The Indian government has generally taken the position that existing intellectual property laws are sufficient. In a 2024 parliamentary response, the Ministry of Commerce stated that India’s current copyright and patent laws are capable of dealing with AI-generated works and that no separate category of AI rights is needed[11]. In other words, the government believes AI creations should fit within the existing legal framework rather than receive special treatment.

Despite this confidence, practical difficulties remain. Suppose a designer types a detailed prompt and carefully refines the AI’s output several times. In that situation, it is easier to argue that the designer contributed creative effort and should be treated as the author. But what if someone simply clicks a button and allows the AI to produce a design automatically? Is pressing “generate” enough to claim copyright? The law does not provide a clear answer.

For now, Indian law seems to follow a simple principle: AI may create the design, but a human must stand behind it.[12] The person who directs, initiates, or controls the process is most likely to receive legal recognition as the author. However, as AI becomes more independent and sophisticated, the gaps in India’s legal framework are becoming increasingly visible.

United Kingdom: “Who Set Up the Show?”

The United Kingdom has one of the most unusual approaches to AI-generated works. Instead of insisting that every copyrighted work must have a human creator, UK law specifically addresses computer-generated creations.

Under Section 9(3) of the Copyright, Designs and Patents Act 1988, when a work is generated by a computer without a human author, the author is deemed to be the person who made the arrangements necessary for creating the work.[13]

Think of it like organizing a fashion show. The models may walk the runway, but the organizer who planned everything receives the credit for making the event happen. Similarly, when AI creates a design, UK law focuses on the person who set up the process rather than the machine itself.

This sounds simple until another copyright requirement enters the picture: originality. Copyright traditionally protects works that reflect human creativity. Yet Section 9(3) applies specifically to works with “no human author.” This creates an awkward legal puzzle. If originality requires human creativity, how can a work with no human author still be original?

The UK government has openly acknowledged this contradiction, and legal scholars continue to debate it. Nevertheless, the provision remains part of UK law.[14]
One of the most important cases in this area is Nova Productions Ltd v Mazooma Games Ltd (2006).[15] The dispute involved computer-generated images produced during gameplay. The court ruled that the programmer who created the software was the author because they had undertaken the arrangements necessary for generating the images. The player, despite influencing what appeared on the screen, was not considered an author because their contribution was too limited.

This decision suggests that the person who designs or controls the system may receive authorship rather than someone who merely interacts with it. However, modern AI tools create a new challenge. When a user enters detailed prompts, edits outputs, and directs the creative process, their contribution may be much greater than that of a video game player.

As a result, UK policymakers increasingly suggest that the person providing prompts and instructions will often be treated as the author. The overall message is clear: the AI gets no legal credit, but the human who organized or directed the process probably does.[16]

United States: “No Human, No Copyright”

If India is flexible and the UK is creative, the United States is strict.

American copyright law is built on a simple idea: copyright exists to protect human creativity. If there is no human author, there is no copyright.

Unlike India and the UK, the United States has no special provision for computer-generated works. The U.S. Copyright Office repeatedly states that human authorship is an essential requirement for copyright protection[17]. An AI system, no matter how intelligent or creative it appears, cannot legally be an author.

Imagine asking an AI to create an original luxury handbag design and then publishing the result exactly as generated. Under current U.S. law, that design may receive no copyright protection because the creative expression came from the AI rather than a human being.

The Copyright Office has reinforced this position through several decisions. In one case, a creator attempted to register an artwork produced entirely by AI. The application was rejected because there was no human author.[18] In another well-known example, the graphic novel Zarya of the Dawn received copyright protection only for the human-written text and the author’s arrangement of the content. The AI-generated images themselves were excluded from copyright[19].

American courts have followed a similar approach. A famous example is Naruto v. Slater, often called the “Monkey Selfie Case[20].” The court held that a monkey who accidentally took photographs could not own copyright because only humans can be authors under copyright law. While the case had nothing to do with AI, it reinforced a broader principle: copyright belongs to people, not non-human creators.

The same reasoning now applies to artificial intelligence. An AI system can be a powerful tool, but it cannot own rights or claim authorship[21].

This does not mean AI-assisted works are completely unprotected. If a human significantly edits, arranges, modifies, or creatively shapes the AI-generated material, those human contributions can receive copyright protection. The key question is always the same: How much creativity came from humans?

For the fashion industry, this means that an AI-generated dress design may be protected only if a designer contributes meaningful creative choices. If the design is produced entirely by AI with little or no human involvement, it will likely remain unprotected and available for anyone to use.

Comparing the Three Approaches

The three countries ultimately agree on one important point: AI is not an author. However, they differ in how they identify the human behind the creation.

India looks for the person who caused the work to be created. The UK looks for the person who made the necessary arrangements. The United States goes further and asks whether a human contributed enough creativity to deserve copyright at all.[22]

If AI were a fashion intern, India and the UK would say, “Great work, but the credit goes to your supervisor.” The United States would respond, “Interesting design, but unless a human was creatively involved, nobody gets copyright.”

As AI continues to transform the fashion industry, these different approaches reveal a common challenge: copyright law was designed for human creators, and the law is still figuring out what to do when the sketchbook belongs to a machine[23].

Case Law Discussion

Laws tell us what should happen, but court cases show us what actually happens when unusual situations land before judges. When it comes to AI-generated fashion designs, there are still very few direct cases anywhere in the world. As a result, courts often rely on older cases involving computers, animals, or other non-human creators to answer modern AI questions[24].

India: Waiting for Its First Big AI Copyright Case

India has not yet had a major court case specifically dealing with AI-generated fashion designs or AI-created artistic works. This means that judges have not directly answered the question of who owns a fashion design produced by artificial intelligence.

For now, Indian lawyers and scholars rely on the Copyright Act and comparisons with earlier cases involving non-human creators. Indian copyright law generally assumes that authors are human beings, even though it contains special provisions for computer-generated works.[25]

One frequently discussed principle comes from older decisions where courts refused copyright protection when the creator was not a human. Courts have indicated that animals, natural forces, or other non-human entities cannot be treated as authors because copyright law is designed to reward human creativity.[26] Following this logic, an AI system acting entirely on its own would also struggle to qualify as an author.

As a result, if an AI-generated fashion design were brought before an Indian court today, the most likely outcome would be that the court searches for the human behind the process the person who instructed, guided, or directed the AI[27]. The machine itself would not receive legal recognition.

In short, India is still waiting for its first landmark AI copyright case. Until then, the law remains a bit like an unfinished outfit: the basic structure exists, but some important details still need tailoring.

United Kingdom: The Video Game Case That Became Important for AI

The most influential UK case on computer-generated works is Nova Productions Ltd v. Mazooma Games Ltd (2006)[28]. Although the dispute had nothing to do with fashion or AI, it provides valuable guidance for understanding who owns computer-generated creations.

The case involved a virtual pool game. As players played the game, the computer automatically generated different images and scenes on the screen. The question was simple but important: Who created those images?

Was it the player, who controlled the game and influenced what appeared on the screen? Or was it the programmer, who designed the software that generated the images?

The court sided with the programmer. It held that the programmer had made the arrangements necessary for creating the images because they designed the game’s visual elements and wrote the software that produced them[29]. The player merely used the system that already existed.

A simple way to understand the court’s reasoning is to imagine a karaoke machine. The singer chooses the song, but they did not compose the music or build the machine. Similarly, the player influenced the game’s output but did not create the system that made the output possible.

The significance of Nova is that it demonstrates how UK courts identify the human behind a computer-generated work[30]. Rather than giving credit to the machine, the law looks for the person who organized, programmed, or arranged the creative process.

For modern AI-generated fashion designs, the same question arises: is the author the AI developer, the user who writes the prompts, or someone else? While Nova does not provide all the answers, it clearly confirms one thing—the computer itself is not the author.

United States: The Famous Monkey Selfie and the Human Authorship Rule

The United States has developed perhaps the clearest position on non-human creators through an unexpectedly famous case: Naruto v. Slater (2018), often called the Monkey Selfie Case[31].

The story sounds like something from a comedy film. A wildlife photographer left his camera unattended, and a macaque monkey named Naruto pressed the shutter button and took several photographs of itself. The resulting selfies became world famous, and a legal dispute followed over who owned the copyright.

The court ultimately ruled that the monkey could not own copyright because the Copyright Act protects works created by human authors. Since Naruto was not human, he could not be recognized as an author.

While the case involved a monkey rather than artificial intelligence, its legal significance extends far beyond wildlife photography. The court reinforced the principle that copyright law is intended for human creators, not animals, machines, or other non-human entities.

If a monkey cannot own copyright in a selfie, the reasoning suggests that an AI system cannot own copyright in a fashion design either[32].

U.S. Copyright Office Decisions: AI Meets a Legal Reality Check

The U.S. Copyright Office has also dealt directly with AI-generated works.

In A Recent Entrance to Paradise (2022), an applicant attempted to register an artwork created entirely by artificial intelligence.[33] The Copyright Office refused the application, explaining that copyright requires human authorship[34]. Since the artwork lacked meaningful human creative contribution, it could not be protected.

A different outcome occurred in Zarya of the Dawn (2023), a graphic novel that combined human-written text with AI-generated images[35]. The Copyright Office allowed copyright protection for the author’s writing and creative arrangement of the work but refused protection for the AI-generated images themselves.

The decision effectively said: “The human parts are protected; the machine-made parts are not.”

These decisions show that the United States is not opposed to AI-assisted creativity. However, it insists that a human must make meaningful creative choices before copyright protection becomes available.

The DABUS Cases: When AI Tried to Become an Inventor

Another important development involved an AI system called DABUS, which was listed as an inventor in patent applications around the world.

The creator of DABUS argued that the AI had independently generated the invention and should therefore be recognized as the inventor. Courts and patent offices rejected this argument, holding that inventors must be human beings unless legislation explicitly states otherwise[36].

Although these cases involved patents rather than copyright, they reveal a broader principle in intellectual property law: machines may assist in innovation, but the law still expects a human being to stand behind the creation.

What Do These Cases Tell Us?

Despite involving video games, monkeys, and AI-generated artworks, all of these cases point to the same conclusion. Courts are willing to protect works created with the assistance of technology, but they are reluctant to recognize technology itself as a creator.

In the UK’s Nova case, the programmer received authorship instead of the computer. In Naruto, the monkey received no copyright because it was not human. In U.S. Copyright Office decisions, AI-generated content was denied protection unless meaningful human creativity was present.[37]

The common message is surprisingly simple: the law may admire what AI can create, but when it comes to copyright ownership, it still wants a human signature on the sketchbook.

Critical Analysis and Findings

The comparison between India, the UK, and the US shows that all three countries agree on one important rule: AI may be smart, but it cannot own copyright. The law still wants a human somewhere in the creative process.

However, the countries differ in how they identify that human. India looks for the person who “caused” the work to be created, while the UK focuses on the person who made the necessary arrangements. The US takes the strictest approach and asks a simple question: “Where is the human creativity?” If there is none, there is no copyright.[38]

The biggest challenge is uncertainty. If a designer spends hours refining prompts and editing AI-generated fashion designs, copyright seems easier to justify. But what if someone simply types a short prompt and clicks “generate”? Is that enough creative effort? Current laws do not provide a clear answer[39].

For the fashion industry, this creates practical problems. Designers and brands using AI may struggle to prove ownership of their creations, while at the same time risking infringement if AI tools are trained on copyrighted designs[40]. It is a bit like borrowing clothes from someone else’s wardrobe without knowing who owns them.

The UK’s system is often criticized because it allows copyright for computer-generated works while copyright law itself is based on human creativity. India faces criticism for relying on legal provisions written long before modern AI existed. The US offers clarity but can be overly strict, leaving some AI-generated works without any protection at all[41].

Overall, the law is trying to fit twenty-first-century technology into twentieth-century rules. While AI can design dresses, create patterns, and generate entire collections, legal systems around the world still insist that copyright belongs to humans, not machines.

Recommendations

As AI becomes more common in fashion design, lawmakers should provide clearer guidance about how much human involvement is required for copyright protection. Simple rules explaining what counts as meaningful creative contribution would reduce confusion for designers and businesses.

India could update its Copyright Act to better define computer-generated works and explain how AI-generated creations should be treated. The UK could clarify its originality requirements to remove contradictions in its current framework. The US could consider limited protections for AI-assisted works while continuing to prioritize human creativity[42].

International cooperation is also important because fashion and AI operate across borders[43]. A designer in Mumbai might use an AI system developed in London and trained on data from New York. Consistent global standards would make ownership rules easier to understand and apply.

In the end, AI may be the newest member of the fashion industry, but for now, the legal spotlight remains firmly on human creators. After all, copyright law still believes that even the smartest machine should not get its own seat on the runway.

Conclusion

AI is rapidly changing the fashion industry, making it possible to create stunning designs with just a few clicks. However, copyright law is still built around a simple idea: creativity belongs to humans, not machines.

As this article has shown, India, the UK, and the US all agree that AI cannot be an author.[44] India gives authorship to the person who causes the work to be created, the UK recognizes the person who makes the necessary arrangements, and the US protects only works that contain meaningful human creativity[45]. In each system, a human must play an important role for intellectual property protection to exist.

For fashion designers, the message is straightforward: AI can be a brilliant assistant, but it cannot legally take the designer’s place. The more creative input a human contributes, the stronger the claim to copyright protection.

As AI technology continues to evolve, laws will need to evolve with it. Future reforms should provide clearer rules on authorship and ownership while ensuring that innovation is encouraged without diminishing the value of human creativity. After all, AI may be able to draw the dress, but the law still wants a human designer to take the bow at the end of the runway.

Bibliography

Cases

Burrow-Giles Lithographic Co v Sarony 111 US 53 (1884).

Naruto v Slater 888 F 3d 418 (9th Cir 2018).

Nova Productions Ltd v Mazooma Games Ltd [2007] EWCA Civ 219.

Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023).

Legislation

Copyright Act 1957 (India).

Copyright Act 1976 (US).

Copyright, Designs and Patents Act 1988 (UK).

Designs Act 2000 (India).

Secondary Sources

Ministry of Commerce and Industry, Government of India, Lok Sabha Unstarred Question No 4266, answered 9 February 2024.

UK Intellectual Property Office, Artificial Intelligence and Intellectual Property: Copyright and Patents Government Response to Consultation (2022).

US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (2023).

World Intellectual Property Organization, WIPO Conversation on Intellectual Property and Artificial Intelligence.

[1] US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[2] Copyright Act 1957, s 2(d)(vi); Copyright, Designs and Patents Act 1988, s 9(3); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[3] Copyright Act 1957 (India); Copyright, Designs and Patents Act 1988 (UK)

[4] Copyright Act 1957, s 2(d)(vi).

[5] Copyright, Designs and Patents Act 1988, s 9(3).

[6] US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[7] Burrow-Giles Lithographic Co v Sarony 111 US 53 (1884).

[8] Naruto v Slater 888 F 3d 418 (9th Cir 2018); Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023).

[9] Copyright Act 1957, s 2(d)(vi).

[10] Copyright (Amendment) Act 1994, which inserted provisions relating to computer-generated works into the Copyright Act 1957

[11] Ministry of Commerce and Industry, Government of India, Lok Sabha Unstarred Question No 4266, answered 9 February 2024.

[12] Copyright Act 1957, s 2(d)(vi).

[13] Copyright, Designs and Patents Act 1988, s 9(3).

[14] UK Intellectual Property Office, Copyright and Artificial Intelligence Consultation (2024).

[15] Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch).

[16] UK Intellectual Property Office, Artificial Intelligence and Intellectual Property: Copyright and Patents—Government Response to Consultation (2022).

[17] US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[18] US Copyright Office Review Board, Re: A Recent Entrance to Paradise (14 February 2022).

[19] US Copyright Office, Zarya of the Dawn Registration Decision Letter (2023).

[20] Naruto v Slater 888 F 3d 418 (9th Cir 2018)

[21] Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023).

[22] Copyright Act 1957, s 2(d)(vi); Copyright, Designs and Patents Act 1988, s 9(3); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[23] World Intellectual Property Organization (WIPO), WIPO Conversation on Intellectual Property and Artificial Intelligence (various sessions).

[24] Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch); Naruto v Slater 888 F 3d 418 (9th Cir 2018); Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023).

[25] Copyright Act 1957, ss 2(aa), 2(d)(vi).

[26] See generally Copyright Act 1957, s 2(d); cf Naruto v Slater 888 F 3d 418 (9th Cir 2018) (illustrating the broader principle that non-human entities cannot claim authorship).

[27] Copyright Act 1957, s 2(d)(vi).

[28] Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch).

[29] Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch).

[30] Copyright, Designs and Patents Act 1988, s 9(3); Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch).

[31] Naruto v Slater 888 F 3d 418 (9th Cir 2018

[32] Naruto v Slater 888 F 3d 418 (9th Cir 2018); Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023)

[33] US Copyright Office Review Board, Re: A Recent Entrance to Paradise (14 February 2022)

[34] US Copyright Office Review Board, Re: A Recent Entrance to Paradise (14 February 2022)

[35] US Copyright Office, Zarya of the Dawn Registration Decision Letter (2023)

[36] Thaler v Perlmutter 687 F Supp 3d 140 (DDC 2023).

[37] Nova Productions Ltd v Mazooma Games Ltd [2006] EWHC 24 (Ch); Naruto v Slater 888 F 3d 418 (9th Cir 2018); US Copyright Office Review Board, Re: A Recent Entrance to Paradise (14 February 2022); US Copyright Office, Zarya of the Dawn Registration Decision Letter (2023)

[38] Copyright Act 1957, s 2(d)(vi); Copyright, Designs and Patents Act 1988, s 9(3); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[39] UK Intellectual Property Office, Copyright and Artificial Intelligence Consultation (2024); World Intellectual Property Organization (WIPO), WIPO Conversation on Intellectual Property and Artificial Intelligence (various sessions).

[40] Ministry of Commerce and Industry, Government of India, Lok Sabha Unstarred Question No 4266, answered 9 February 2024; US Copyright Office, Copyright and Artificial Intelligence, Part 2: Copyrightability (2025)

[41] UK Intellectual Property Office, Copyright and Artificial Intelligence Consultation (2024); Copyright Act 1957, s 2(d)(vi); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190

[42] UK Intellectual Property Office, Copyright and Artificial Intelligence Consultation (2024); US Copyright Office, Copyright and Artificial Intelligence, Part 2: Copyrightability (2025).

[43] World Intellectual Property Organization (WIPO), WIPO Conversation on Intellectual Property and Artificial Intelligence (various sessions).

[44] Copyright Act 1957, s 2(d)(vi); Copyright, Designs and Patents Act 1988, s 9(3); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

[45] Copyright Act 1957, s 2(d)(vi); Copyright, Designs and Patents Act 1988, s 9(3); US Copyright Office, Copyright Registration Guidance: Works Containing Material Generated by Artificial Intelligence (16 March 2023) 88 Fed Reg 16190.

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