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D.C. Circuit Holds that Works Created Solely by AI are Not Copyrightable

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On March 18, 2025, the D.C. Circuit Court of Appeals affirmed the D.C. District Court’s and U.S. Copyright Office’s decisions,...

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We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.

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On March 18, 2025, the D.C. Circuit Court of Appeals affirmed the D.C. District Court’s and U.S. Copyright Office’s decisions, holding that a copyrighted work cannot be authored exclusively by an AI system.Read the full <a href="https://mofotech.mofo.com/topics/circuit-holds-that-works-created-solely-by-ai-are-not-copyrightable" target="_blank">blog post</a>.

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Clients turn to Joe Gratz to handle trailblazing litigation where copyright and trademark law meet new technologies. An experienced litigator, Joe draws on his strong technical background to distill complex issues into simple, accurate concepts for judges, juries, and clients. Joe’s cases have set key precedents in Internet law, from the Google Books case that laid the groundwork for today’s generative AI innovations to key cases establishing the boundaries of intermediary liability. In addition to representing their interests in the courtroom, Joe helps his clients navigate their thorniest product counseling puzzles to reduce the risk of litigation.His appellate victory in Long v. Facebook set the standard for platforms in carrying out DMCA removals of user-generated content. And Joe’s win in Stevens v. CoreLogic established limitations on DMCA 1202 claims that have since been adopted by numerous other courts. His amicus brief on behalf of independent booksellers was cited by the Supreme Court in its opinion in Wiley v. Kirtsaeng, and he has submitted amicus briefs in other copyright cases on behalf of Center for Democracy & Technology (in Oracle v. Google) and on behalf of art law professors (in Warhol v. Goldsmith).A recognized commentator on copyright and internet law, Joe was selected as an advisor for the American Law Institute’s project to develop a Restatement of Copyright, and serves on the Advisory Board of the Electronic Frontier Foundation. He frequently speaks on emerging issues in Internet law and was called upon by the Senate Judiciary Committee in 2020 to testify about the interaction between the DMCA 512 safe harbor and fair use. Joe was the 2022 recipient of the California Lawyers Association’s IP Vanguard award, presented to one private practitioner each year for achievements at the forefront of emerging issues in intellectual property law.

Joseph Gratz

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Sara Talebian is an associate in the Intellectual Property Litigation Group based in the firm’s Washington, D.C. office. Sara focuses her practice on copyrights, trademarks, and rights of publicity, as well as breach of contract claims and tort causes of action.Sara is proficient in all phases of civil litigation, from initial pleadings and discovery compliance to expert and fact deposition preparation, motions practice, trial, post-trial, and appellate work. Her comprehensive legal capabilities enable her to effectively navigate the intricacies of litigation and provide strategic counsel to her clients. She operates in a diverse set of industries, having represented clients in the entertainment, construction, consumer protection, advertising, and environmental sectors.Sara earned her J.D. from American University Washington College of Law, where she graduated cum laude and was recognized for her academic excellence with the Mussey Prize for the highest scholastic average in her 3L year. She also served as the editor-in-chief of the Administrative Law Review. Sara earned a Bachelor of Music in Music Education from Berklee College of Music, graduating summa cum laude as the top student in her major.