Judicial Responses to AI-Generated Works: A Comparative Case Law Analysis on Copyright

As artificial intelligence (AI) increasingly contributes
to the creation of original content, legal systems are under
pressure to determine whether and how such outputs can be
protected by copyright. While much of the academic debate
focuses on future legislative reforms, courts and existing legal
frameworks are already being tested by real disputes. This paper
examines how different jurisdictions, namely, the United
States, the United Kingdom, the European Union, Australia,
and China, approach the copyright protection of AI-generated
works, both at the level of underlying legal doctrine and
through judicial interpretation. The first part of the paper outlines
the key principles of copyright law in each system, including
definitions of authorship, standards of originality, and relevant
exceptions or limitations that may apply to AI training
and output. The second part shifts to case law, examining how
courts have applied or challenged these principles when addressing
AI-generated work. In doing so, the paper focuses on
three core legal issues: whether AI-generated works can meet
originality thresholds, how authorship and ownership are assigned,
and how the expression–idea dichotomy is interpreted
in this context. It is within this judicial context that the present
study situates its analysis, using case law as the primary lens
to examine how legal systems are grappling with the growing
presence of AI in creative processes. By comparing these legal
systems and judicial approaches, the paper demonstrates that