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Ryan Abbott, Esq. Brown, Neri, Smith & Khan, LLP into binding legal contracts and thus cannot meet this requirement. Second, the work-for-hire doctrine only speaks to the identity of a work’s owner, not whether a work is protected by copyright. As explained above, the statute requires that a work contain human authorship. In sum, the Work is not a work made for hire because it is neither a “work of authorship” nor a work created “for hire.”

Much of Thaler’s second request amounts to a policy argument in favor of legal protection for works produced solely by artificial intelligence. He cites to no case law or other precedent that would undermine the Office’s construction of the Copyright Act. Because copyright law as codified in the 1976 Act requires human authorship, the Work cannot be registered.

IV.CONCLUSION

For the reasons stated herein, the Review Board of the United States Copyright Office affirms the refusal to register the copyright claim in the Work. Pursuant to 37 C.F.R. § 202.5(g), this decision constitutes final agency action in this matter.