ABSTRACT
Law makers and administrative agencies around the globe have discussed whether the use of copyrighted content for the training of generative AI is or should be permissible without the rights holder’s consent, and whether their copyright laws should be amended to give rights holders either more or less say over such uses of their works. More than once, law makers invoked the laws of other countries to advocate for or to caution against change. Countries which want to participate in the value creation associated with generative AI and which seek to attract companies that develop such applications might want to make sure that their copyright law does not put them at a competitive disadvantage vis-à-vis other countries. This article examines applicable rules in those parts of the world which call themselves home to or are particularly vocal in their wish to attract AI companies – namely the US, Canada, the UK, the EU, Israel, China, Singapore, and Japan. The findings are presented in the form of six theses.
de la Durantaye, Katharina, Control and Compensation. A Comparative Analysis of Copyright Exceptions for Training Generative AI (June 17, 2024).
Leave a Reply