With the tremendous growth of technology our society has been evolving, but changes in law has not been always adaptive. Traditionally, the computer generated works were merely considered a tool to support creative process just like pen or paper so the question of authorship was never raised. However creative works that were produced only by humans, have now been originated by Artificial Intelligence(AI) that takes various decisions without human involvement and is no longer a tool to support creative works by humans. The Copyright Act, 1957 defines ‘author’ with reference to copyrightable works but does not mention anything about legal personality of the author. Therefore, it is crucial to explore whether AI can be included as an author of copyrightable works and if so what can be the implications of granting authorship to AI. Further, the research will analyse the suitability of present law to deal with AI authorship and if there is any need to change or revaluate the copyright laws in light of technological advancements in digital era.
INTRODUCTION
It has always been unthinkable for humans to
identify ‘intelligence’ without including human interference for years. But
with the advent of technology and its intrinsic growing nature we in this
digital era have something known as a “Artificial Intelligence” which exhibits
intelligent conduct of performing complex tasks without any human intervention.
On the other hand, Intellectual Property Rights have been considered as an
essential right since ages for giving incentive to the creator who adds value
to the society through his contribution. The dilemma between them arose when AI
started creating creative works without human involvement. The study is
significant to understand whether the copyrights law can consider AI as the
creator of copyright work and if so then what can be the possible legal issues
in such cases, followed by effective suggestions to meet the need of problem.
As we know that Artificial Intelligence is
already being used by many companies to create gaming, music etc which could be
considered free of copyright consequently this will have negative commercial
impact therefore the research holds significance for commercial sector.
LEGAL ENTITY OF ARTIFICIAL INTELLIGENCE
The very first issue at hand in
this IPR regime is whether Artificial Intelligence can be granted a legal
entity. According to Black Law Dictionary, legal entity can be defined as “a
lawful or legally standing association, corporation, partnership,
proprietorship, trust, or individual. It has legal capacity to (1) enter into
agreements or contracts, (2) assume obligations, (3) incur and pay debts, (4)
sue and be sued in its own right, and (5) to be accountable for illegal
activities.”[1]
Until recently law has mostly recognized natural person for
granting legal entity however recently it gave legal recognition to AI robot
named Sofia who was granted full citizenship though it was heavily criticized
on the grounds of violation of human rights.[2][3] Time and again common law
experts have emphasized that only a natural person can be identified as a legal
person thus, the issue of personhood in relation to AI became a substantial
point of discussion.
The word “Juristic Person” itself means giving recognition
to a person in law which it is not otherwise. The concept of legal personality
cannot be limited to non-human entity but can be used on an artificially
created person such as idols, groups of humans, funds, companies etc. In such
cases the law knows that they cannot enter into agreements or sue anyone
therefore it appoints agent who act on the behalf and carry out such tasks.[4]In several cases, Supreme
Court of India has recognised legal identity of religious idols making them
capable of paying taxes or holding property through their representatives.[5] The same logic maybe
applied to AI for providing them legal recognition as they being more capable
than idols.
While many legislators have argued that they need to have
intelligence at par with humans for legal personhood, however such argument can
be rejected on the grounds that even young toddlers and people having serious
cognitive defects are given legal personhood in comparison to AI which has high
level of intelligence and cognitive skills[6]. Law has always been
dynamic, if AI is provided recognition in law it will have positive impacts in this
technological age society considering that the future is AI thereby encouraging
people to contribute in AI research field.[7]
Can AI be recognised as a creator of Copyrights work in Indian laws
The requirements for a work to be copyrighted is that the
expression of ideas must be original, tangible and creative enough in nature so
that they can be perceptibly differentiated. The intellectual property rights depend
upon ownership i.e. the copyright ownership must be claimed either by the owner
himself or he must have succeeded the rights of owner of copyrights work. The
principal purpose of providing such rights are to incentivize people who create
creative works which are a valuable contribution to the society and to avoid
misappropriation of work created through immense hard work. The Indian
Copyright Act defines work under section 2(y)as “literary, dramatic, musical or
artistic work, a cinematograph film, a sound recording” which is further
extended by section 2(o) to include “computer programs, table compilations
etc”.
In the renowned case of Macaque selfie[8] ,where a monkey
mistakenly took a selfie which arose the issue of whether animals can be
considered an a creator of copyrights work. Here, different stands had been
taken by PETA and the photographer in the court ultimately the court settled
the issue and held that an animal cannot be the creator and the picture was put
in public domain.
In the case of Eastern Book Company v. D.B
Modak[9]
the doctrine of ‘modicum of creativity’ was laid down and was recognised as an
essential criteria for copyright. It says that ‘original’ does not need to be
original idea but it depends on the amount of skills and labour involved while
creating the copyrightable works[10]. Therefore, the work of
selection, coordination and arrangement of pre-existing data can be copyrighted
as the product made by putting skills or labour is different from what was
pre-existing data.
There has been a significant history of machine helping
humans to create works but what differentiates AI from machine is that machines
only performs limited set of works under human control whereas AI applies its
knowledge to a new set of facts to produce original or derivative work. In
1993, a writer Jacqueline Susann wrote the book ‘Just this Once’ in which
computer program helped her as a result some new creative work was used
collaboratively. Recently, we have seen AI producing music mostly using deep
learning networks such as Amper Music, Spotify’s Creator etc [11]. The music created by AI
here is completely original with no inputs from the users. Besides the creation
of AI chat box by facebook developed its own language and communicates with
other chat boxes this shows at what unexpected rate AI has been growing. The
pertinent question here lies is AI works eligible for copyright protection and
to get that claim work should be solely produced by AI without any human
involvement. Generally, AI produced work ticks all the boxes required for
copyright protection in terms of originality of tangible content but the
current copyright law does not identify AI as a legal entity.
Further, there has been a recent trend of AI development in
India, when ministry of Commerce and Industry had set up 18-member Task force
on advising for creation of framework to promote the deployment of AI.
Moreover, in 2018 NITI Aayog released the discussion paper “India’s National
Strategy for Artificial Intelligence” promoting the strategy of economic,
social and inclusive growth, while establishing the brand of #AIforAll[12].However, there has been
no discussion since then on the legal implications of AI. In addition, a tender
was posted on the website of IPO for inviting Expression of Interest for making
AI, Blockchain etc[13].
Position for AI
ownership in other jurisdictions
The Registrar of copyright at US Copyright identified the
issue as early as 1965 of human authorship where computer is merely used as an
instrument and whether the traditional character of authorship is given when
the work is done by machine without human intervention[14]. Whereas in UK, the
Copyright Designs and Patents Act,1988 provides that the for the copyrightable
works the author shall be taken to be the person for whom the creative works
has been undertaken.[15]
Moreover, New Zealand laws provides protection to all
original works even if they are created by AI systems or robots[16]. It defines computer
generated work (section 2) as generated such that there is no human creator
involved. However, section 5 clarifies for the computer-generated work that it
is the person by whom the arrangement for the creation are taken up[17].The US law holds that
authorship is a unique human process and cannot be given to intelligent machines,
similar view has been given in case of patent[18].To combine it with the Compendium of US Copyright Office
which states that the office will not register works which are merely produced
by mechanical process or machine that operates randomly without any
intervention of human beings[19].
Issues in Identifying AI as The Owner of
Copyrightable Works
There are several issues that begin
to pour in when one recognises AI as the owner of copyright. In case of
infringement of work that has already been produced the producer of original
art wants to sue should sue user of the AI or the AI itself and what can be
valid defences in case of the copied work if not intentionally created becomes
a relevant question of discussion in this AI surrounded world.
*No legal entity
It is worth bearing in mind that there is no useful end to
provide copyright ownership to AI as it cannot protect its creation as it has
no power to sue in case of infringement. Currently AI has not been identified
as a legal entity. There is still lack of human like intellectual abilities as
just knowledge in a particular area like playing chess or just creating music
will not be sufficient presently for considering to grant status of legal
personhood[20] .
AI need a human developer which is also recognised under copyright law to deal
with various issues of copyright protection.
*Lack of social
& financial motivation for AI
AI produces multiple creations in no time which implies
there is no financial or social motivation for an AI to have a copyright
protection unlike the human owners of copyright[21][22]Arthur Miller also points
out that since, “since these software and machines” currently need no such
incentive to create work as there can be no copyright awarded to such entities”[23].
* Sweat and Brow
theory
The sweat & brow
theory which is substantial for a copyright protection is not used much in an
AI creation. Sweat & Brow theory implies simple diligence or labour
involved during the creation of particular creative work which stands contrary
to the AI creation that is done in just a click of a button. It is still
questionable that it used substantial labour or not during creation.
CONCLUSION
Artificial Intelligence is growing at such a fast
rate that it has taken a predominant role in lives of many individuals. It is
quite evident that AI will play even a bigger and substantial part of our lives
in the foreseeable future ahead. Therefore, there is a dire need to find
effective mechanism for creative works developed in international markets. A
relevant question in today’s time is to whom the ownership of intellectual
property right be given, the Artificial Intelligence itself or to its developer
or keep it in public domain?
If the ownership of copyright is provided to the developer of AI it goes against the basic idea of copyright laws as it was not the developer who conceived the idea and produced the creative works thus, this seems illogical. Secondly, if we give ownership rights to AI then it does not coincide with the purpose of law of protecting rights of creator by giving them incentives. Lastly, to put such creative work in public domain would serve the best to public in general according to advancement in the present times. There still might be issues of commercial viability in putting work under public domain but nevertheless we know the future of AI is bright it needs to develop itself more in terms of being more than mechanical product of machines. The present role of playing games, creating artistic work or producing is not sufficient to grant ownership of copyrightable work, they must show emotional intelligence as well to make them capable enough of actually replacing the humans. It is important to encourage growth in AI where they could perfectly replace human beings in creating intellectual property rights which essentially was introduced to reward the skills and labour of a being. Therefore, at present AI is not equipped enough to be termed as an owner of Copyright work however, looking at the rate at which AI is developing the future is near where we can include AI as the owner of copyright works.
*The Author is a Student of LL.M at Hidayatullah National Law University, Raipur.
Disclaimer: The views, thoughts, and opinions expressed in the text belong solely to the author and not to the Jurisedge Academy.
Readers may submit his/her blog for publication. Click Here or Scan the QR Code to submit your Manuscript.
[1] 256 Legal Entity, Black’s Law
Dictionary (10th ed.2014)
[2] 257 Zara Stone, Everything You
Need to Know About Sofia, The World’s First Robot Citizen, Forbes (Nov.
7,2017,12:22 PM)
[4] Paton, George Whitecross, A
Textbook of Jurisprudence, 349,350 David P,Derham et al,eds, 3rd
edition) (1967)
[5]
Yogrndranath Naskar v. CIT, AIR 1969 SC 1089(India)
[6] Elizabeth L. Decoux, In the Valley
of the Dry Bones: Reuniting the World
[7] Ryan Abbott, I think, Therefore I
Invent: Creative Computers & the Future of Patent Law,57 B.C. L.Rev.1079
(2016)
[8] Naruto et al v. David Slater, No.
16-15469, 2018 WL 190214(9th Cir. Apr. 23,2018)
[9] Eastern Book Company v. D.B. Modak
(2018) 1 SCC 1(India)
[10] London Press Limited v. University
Tutorial Press Limited, [1916] 2 Ch. 601(U.K.); Macmillan &Company v. K
& J. Cooper, AIR 1924 PC 75(India)
[11] Dani Deahl,How AI-Generated Music
is Changing The Way Hits Are Made, The Verge (Aug. 31,2018, 9:00AM), https://www.theverge.com/2018/8/31/17777008/
artificial-intelligence-taryn-southern-amper-music
[19] US Copyright office Practices,
Compendium,(2017) s 312 (3)
[20] Woodrow Barfield, Issues of Law
for Software Agents within Virtual environments, 14(6) Presence: Tele operators
& Virtual Env’ts, 741 (2005)
[21] Evan H. Farr,Copyrightablity of
Computer-Created Works, 15 Rutgers Comp. & Tech. LJ. 63, 65 (1989)
[22] Naruto et al v. David Slater, No.
16-15469, 2018 WL 190214(9th Cir. Apr. 23,2018)
[23] Arthur R. Miller, Copyright
Protection for Computer Programs, Databases, and Computer Generated Works: Is
Anything New Since CONTU? 106 Harv. L.Rev. 977(1993)
Saurabh Kumar
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Author- Kirti Jaggi*
ABSTRACT
With the tremendous growth of technology our society has been evolving, but changes in law has not been always adaptive. Traditionally, the computer generated works were merely considered a tool to support creative process just like pen or paper so the question of authorship was never raised. However creative works that were produced only by humans, have now been originated by Artificial Intelligence(AI) that takes various decisions without human involvement and is no longer a tool to support creative works by humans. The Copyright Act, 1957 defines ‘author’ with reference to copyrightable works but does not mention anything about legal personality of the author. Therefore, it is crucial to explore whether AI can be included as an author of copyrightable works and if so what can be the implications of granting authorship to AI. Further, the research will analyse the suitability of present law to deal with AI authorship and if there is any need to change or revaluate the copyright laws in light of technological advancements in digital era.
INTRODUCTION
It has always been unthinkable for humans to identify ‘intelligence’ without including human interference for years. But with the advent of technology and its intrinsic growing nature we in this digital era have something known as a “Artificial Intelligence” which exhibits intelligent conduct of performing complex tasks without any human intervention. On the other hand, Intellectual Property Rights have been considered as an essential right since ages for giving incentive to the creator who adds value to the society through his contribution. The dilemma between them arose when AI started creating creative works without human involvement. The study is significant to understand whether the copyrights law can consider AI as the creator of copyright work and if so then what can be the possible legal issues in such cases, followed by effective suggestions to meet the need of problem.
As we know that Artificial Intelligence is already being used by many companies to create gaming, music etc which could be considered free of copyright consequently this will have negative commercial impact therefore the research holds significance for commercial sector.
LEGAL ENTITY OF ARTIFICIAL INTELLIGENCE
The very first issue at hand in this IPR regime is whether Artificial Intelligence can be granted a legal entity. According to Black Law Dictionary, legal entity can be defined as “a lawful or legally standing association, corporation, partnership, proprietorship, trust, or individual. It has legal capacity to (1) enter into agreements or contracts, (2) assume obligations, (3) incur and pay debts, (4) sue and be sued in its own right, and (5) to be accountable for illegal activities.”[1]
Until recently law has mostly recognized natural person for granting legal entity however recently it gave legal recognition to AI robot named Sofia who was granted full citizenship though it was heavily criticized on the grounds of violation of human rights.[2] [3] Time and again common law experts have emphasized that only a natural person can be identified as a legal person thus, the issue of personhood in relation to AI became a substantial point of discussion.
The word “Juristic Person” itself means giving recognition to a person in law which it is not otherwise. The concept of legal personality cannot be limited to non-human entity but can be used on an artificially created person such as idols, groups of humans, funds, companies etc. In such cases the law knows that they cannot enter into agreements or sue anyone therefore it appoints agent who act on the behalf and carry out such tasks.[4]In several cases, Supreme Court of India has recognised legal identity of religious idols making them capable of paying taxes or holding property through their representatives.[5] The same logic maybe applied to AI for providing them legal recognition as they being more capable than idols.
While many legislators have argued that they need to have intelligence at par with humans for legal personhood, however such argument can be rejected on the grounds that even young toddlers and people having serious cognitive defects are given legal personhood in comparison to AI which has high level of intelligence and cognitive skills[6]. Law has always been dynamic, if AI is provided recognition in law it will have positive impacts in this technological age society considering that the future is AI thereby encouraging people to contribute in AI research field.[7]
Can AI be recognised as a creator of Copyrights work in Indian laws
The requirements for a work to be copyrighted is that the expression of ideas must be original, tangible and creative enough in nature so that they can be perceptibly differentiated. The intellectual property rights depend upon ownership i.e. the copyright ownership must be claimed either by the owner himself or he must have succeeded the rights of owner of copyrights work. The principal purpose of providing such rights are to incentivize people who create creative works which are a valuable contribution to the society and to avoid misappropriation of work created through immense hard work. The Indian Copyright Act defines work under section 2(y)as “literary, dramatic, musical or artistic work, a cinematograph film, a sound recording” which is further extended by section 2(o) to include “computer programs, table compilations etc”.
In the renowned case of Macaque selfie[8] ,where a monkey mistakenly took a selfie which arose the issue of whether animals can be considered an a creator of copyrights work. Here, different stands had been taken by PETA and the photographer in the court ultimately the court settled the issue and held that an animal cannot be the creator and the picture was put in public domain.
In the case of Eastern Book Company v. D.B Modak[9] the doctrine of ‘modicum of creativity’ was laid down and was recognised as an essential criteria for copyright. It says that ‘original’ does not need to be original idea but it depends on the amount of skills and labour involved while creating the copyrightable works[10]. Therefore, the work of selection, coordination and arrangement of pre-existing data can be copyrighted as the product made by putting skills or labour is different from what was pre-existing data.
There has been a significant history of machine helping humans to create works but what differentiates AI from machine is that machines only performs limited set of works under human control whereas AI applies its knowledge to a new set of facts to produce original or derivative work. In 1993, a writer Jacqueline Susann wrote the book ‘Just this Once’ in which computer program helped her as a result some new creative work was used collaboratively. Recently, we have seen AI producing music mostly using deep learning networks such as Amper Music, Spotify’s Creator etc [11]. The music created by AI here is completely original with no inputs from the users. Besides the creation of AI chat box by facebook developed its own language and communicates with other chat boxes this shows at what unexpected rate AI has been growing. The pertinent question here lies is AI works eligible for copyright protection and to get that claim work should be solely produced by AI without any human involvement. Generally, AI produced work ticks all the boxes required for copyright protection in terms of originality of tangible content but the current copyright law does not identify AI as a legal entity.
Further, there has been a recent trend of AI development in India, when ministry of Commerce and Industry had set up 18-member Task force on advising for creation of framework to promote the deployment of AI. Moreover, in 2018 NITI Aayog released the discussion paper “India’s National Strategy for Artificial Intelligence” promoting the strategy of economic, social and inclusive growth, while establishing the brand of #AIforAll[12].However, there has been no discussion since then on the legal implications of AI. In addition, a tender was posted on the website of IPO for inviting Expression of Interest for making AI, Blockchain etc[13].
Position for AI ownership in other jurisdictions
The Registrar of copyright at US Copyright identified the issue as early as 1965 of human authorship where computer is merely used as an instrument and whether the traditional character of authorship is given when the work is done by machine without human intervention[14]. Whereas in UK, the Copyright Designs and Patents Act,1988 provides that the for the copyrightable works the author shall be taken to be the person for whom the creative works has been undertaken.[15]
Moreover, New Zealand laws provides protection to all original works even if they are created by AI systems or robots[16]. It defines computer generated work (section 2) as generated such that there is no human creator involved. However, section 5 clarifies for the computer-generated work that it is the person by whom the arrangement for the creation are taken up[17].The US law holds that authorship is a unique human process and cannot be given to intelligent machines, similar view has been given in case of patent[18].To combine it with the Compendium of US Copyright Office which states that the office will not register works which are merely produced by mechanical process or machine that operates randomly without any intervention of human beings[19].
Issues in Identifying AI as The Owner of Copyrightable Works
There are several issues that begin to pour in when one recognises AI as the owner of copyright. In case of infringement of work that has already been produced the producer of original art wants to sue should sue user of the AI or the AI itself and what can be valid defences in case of the copied work if not intentionally created becomes a relevant question of discussion in this AI surrounded world.
*No legal entity
It is worth bearing in mind that there is no useful end to provide copyright ownership to AI as it cannot protect its creation as it has no power to sue in case of infringement. Currently AI has not been identified as a legal entity. There is still lack of human like intellectual abilities as just knowledge in a particular area like playing chess or just creating music will not be sufficient presently for considering to grant status of legal personhood[20] . AI need a human developer which is also recognised under copyright law to deal with various issues of copyright protection.
*Lack of social & financial motivation for AI
AI produces multiple creations in no time which implies there is no financial or social motivation for an AI to have a copyright protection unlike the human owners of copyright[21] [22]Arthur Miller also points out that since, “since these software and machines” currently need no such incentive to create work as there can be no copyright awarded to such entities” [23].
* Sweat and Brow theory
The sweat & brow theory which is substantial for a copyright protection is not used much in an AI creation. Sweat & Brow theory implies simple diligence or labour involved during the creation of particular creative work which stands contrary to the AI creation that is done in just a click of a button. It is still questionable that it used substantial labour or not during creation.
CONCLUSION
Artificial Intelligence is growing at such a fast rate that it has taken a predominant role in lives of many individuals. It is quite evident that AI will play even a bigger and substantial part of our lives in the foreseeable future ahead. Therefore, there is a dire need to find effective mechanism for creative works developed in international markets. A relevant question in today’s time is to whom the ownership of intellectual property right be given, the Artificial Intelligence itself or to its developer or keep it in public domain?
If the ownership of copyright is provided to the developer of AI it goes against the basic idea of copyright laws as it was not the developer who conceived the idea and produced the creative works thus, this seems illogical. Secondly, if we give ownership rights to AI then it does not coincide with the purpose of law of protecting rights of creator by giving them incentives. Lastly, to put such creative work in public domain would serve the best to public in general according to advancement in the present times. There still might be issues of commercial viability in putting work under public domain but nevertheless we know the future of AI is bright it needs to develop itself more in terms of being more than mechanical product of machines. The present role of playing games, creating artistic work or producing is not sufficient to grant ownership of copyrightable work, they must show emotional intelligence as well to make them capable enough of actually replacing the humans. It is important to encourage growth in AI where they could perfectly replace human beings in creating intellectual property rights which essentially was introduced to reward the skills and labour of a being. Therefore, at present AI is not equipped enough to be termed as an owner of Copyright work however, looking at the rate at which AI is developing the future is near where we can include AI as the owner of copyright works.
*The Author is a Student of LL.M at Hidayatullah National Law University, Raipur.
Disclaimer: The views, thoughts, and opinions expressed in the text belong solely to the author and not to the Jurisedge Academy.
Readers may submit his/her blog for publication. Click Here or Scan the QR Code to submit your Manuscript.
[1] 256 Legal Entity, Black’s Law Dictionary (10th ed.2014)
[2] 257 Zara Stone, Everything You Need to Know About Sofia, The World’s First Robot Citizen, Forbes (Nov. 7,2017,12:22 PM)
[3] India recognises AI as co-author of copyrighted artwork, https://www.managingip.com,
[4] Paton, George Whitecross, A Textbook of Jurisprudence, 349,350 David P,Derham et al,eds, 3rd edition) (1967)
[5] Yogrndranath Naskar v. CIT, AIR 1969 SC 1089(India)
[6] Elizabeth L. Decoux, In the Valley of the Dry Bones: Reuniting the World
[7] Ryan Abbott, I think, Therefore I Invent: Creative Computers & the Future of Patent Law,57 B.C. L.Rev.1079 (2016)
[8] Naruto et al v. David Slater, No. 16-15469, 2018 WL 190214(9th Cir. Apr. 23,2018)
[9] Eastern Book Company v. D.B. Modak (2018) 1 SCC 1(India)
[10] London Press Limited v. University Tutorial Press Limited, [1916] 2 Ch. 601(U.K.); Macmillan &Company v. K & J. Cooper, AIR 1924 PC 75(India)
[11] Dani Deahl,How AI-Generated Music is Changing The Way Hits Are Made, The Verge (Aug. 31,2018, 9:00AM), https://www.theverge.com/2018/8/31/17777008/ artificial-intelligence-taryn-southern-amper-music
[12] Pankaj Soni and Kartikay Vikrant Singh, ‘Are We Ready for AI Disruption? An Indian Patent Law Perspective’ (Iam-media.com,2018) < https://www.iam-media.com/are-we-ready-ai-disruption-indian-patent-law-perspective >accessed 7 May 2019
[13] Intellectual Property and Technology Law Updates’ (Singhassociates.in,2018) http://www.singhassociates.in/UploadImg/NewaImages/IPR-September-18.pdf
[14] The Library of Congress, Report of the Register of Copyrights for the Fiscal Year Ending June 30, 1965 (sixty-eighth report) https://copyright.gov/report/annual/archieve/ar-1965.pdf
[15] Copyrights Designs and Patent Act 1988, s 9(3)
[16] Copyright Act, 1994, S2
[17] Copyright Act 1994,s 5(2)(a)
[18] Townsend v. Smith, 36 F.2d 292
[19] US Copyright office Practices, Compendium,(2017) s 312 (3)
[20] Woodrow Barfield, Issues of Law for Software Agents within Virtual environments, 14(6) Presence: Tele operators & Virtual Env’ts, 741 (2005)
[21] Evan H. Farr,Copyrightablity of Computer-Created Works, 15 Rutgers Comp. & Tech. LJ. 63, 65 (1989)
[22] Naruto et al v. David Slater, No. 16-15469, 2018 WL 190214(9th Cir. Apr. 23,2018)
[23] Arthur R. Miller, Copyright Protection for Computer Programs, Databases, and Computer Generated Works: Is Anything New Since CONTU? 106 Harv. L.Rev. 977(1993)
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