The Copyrightability Issue of AI-Generated Content: A Comparative Study (EU, US, China) and Legislative Responses

Abstract

Artificial intelligence (AI) is advancing at an astonishingly rapid pace. The rise of generative artificial intelligence (Generative AI) has sparked numerous issues and challenges, as its creations pose a profound impact on the anthropocentrism and originality standards inherent in traditional copyright law. Currently, conventional copyright law is no longer adequate to address the challenges brought by Generative AI. The purpose of this study is to explore the similarities and differences in legal rulings and regulations regarding AI-Generated Content (AIGC) in the European Union, the United States, and China, and to investigate the issue of copyrightability of AI-generated outputs. Against the backdrop of globalization, this paper proposes approaches and relevant recommendations such as international collaboration, legislative updates, standard unification, and the establishment of new judicial framework. These measures are designed to address the challenges and opportunities brought about by Generative AI and content and content generation technologies, safeguard the innovative vitality and long-term development of the industry, and promote the technological advancement of Generative AI and economic growth.