Navigating the legal landscape of AI copyright: a comparative analysis of EU, US, and Chinese approaches

Abstract This paper compares AI copyright approaches in the EU, US, and China, evaluating their effectiveness and challenges. It examines the recognition of AI-generated works as copyrightable and the exclusive rights of copyright owners to reproduce, distribute, publicly display, and perform such works. Differences in approaches, such as recognizing AI as a sui generis right holder in the EU and the broad fair use doctrine in the US, are highlighted. This paper evaluates strengths and weaknesses of each approach, including enforcement and ownership of copyright in AI-generated works, and clarifies issues related to AI and copyright. While the EU and US have more developed legal frameworks for AI copyright than China, all three approaches face challenges that need addressing. This paper concludes by providing insight into the legal landscape of AI copyright and steps necessary for effective protection and use of AI-generated works.