Comparative Study on the Ownership of Copyright of Artificial Intelligence-Generated Works

This article studies the question of copyright ownership for works produced by artificial intelligence. Taking China, the United States, and the European Union as the research subjects, a systematic analysis of the legislative provisions, administrative practices, and judicial precedents in each jurisdiction is conducted, concerning the copyrightability of AI-generated works and the question of rights attribution. On the basis of comparative analysis, this paper offers a theoretical review of the core disputes from the standpoints of the Lockean labour theory, the Hegelian personality theory, and the utilitarian theory. It constructs an analytical framework for distinguishing AI-assisted works from works generated autonomously by AI, with the substantiality of human participation as the core criterion, and puts forward a system of recommendations centered on a hierarchical ownership model. It advocates attributing copyright to the users of AI-assisted works that involve substantial human participation, establishing a special rights system with a shorter protection term for purely AI-generated works, and promoting the achievement of international coordinated consensus within the framework of the World Intellectual Property Organization, in keeping with the call of the Initiative for open, fair, and effective governance of artificial intelligence by all states.