Here is the complete legal memorandum drafted using the provided prompt framework: # MEMORANDUM TO: Business Stakeholder FROM: Legal Research — AI-Assisted Analysis DATE: March 25, 2026 RE: Whether AI-heavy marketing images created from text prompts plus minor Photoshop edits are protected by U.S. copyright law, and what that means for DMCA takedowns against competitors using similar visuals ## I. EXECUTIVE SNAPSHOT The most likely answer is no broad copyright claim exists in the AI-generated image as a whole on the facts provided. Under current U.S. Copyright Office guidance and the D.C. Circuit’s 2025 decision in Thaler, copyright requires human authorship, and prompts alone generally do not supply enough human control over the image’s expressive elements. A company may still have a narrower claim in human-authored contributions, such as sufficiently original selection, arrangement, compositing, or meaningful post-generation edits, but those rights are limited to the human-authored aspects and do not automatically cover the AI-generated material itself. On the present facts, “text prompts and minor Photoshop edits” points toward either no registrable image authorship or only thin protection, which makes DMCA notices against merely “similar” visuals materially risky. Confidence is medium because the answer turns heavily on the actual extent of human editing, the exact final asset, and whether the competitor reused the same image or only a similar concept. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) ## II. ISSUES PRESENTED AND SCOPE CONTROL Primary issue: whether a company may claim copyright protection under United States federal copyright law in marketing images where the image generation was driven largely by AI text prompts and the human contribution consisted of only minor Photoshop edits. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) Necessary sub-issues: 1. Whether the startup’s workflow contains sufficient human authorship to make any part of the ad image copyrightable. ([Kantor Paten dan Merek AS][2]) 2. If some copyright exists, what the scope of protection is: the whole image, only specific edits, or only the human-created selection, coordination, and arrangement of elements. ([Kantor Paten dan Merek AS][2]) 3. Whether DMCA takedowns aimed at competitors using “similar visuals” are supportable, and what exposure exists if the copyright claim was overstated. ([GovInfo][3]) Excluded adjacent issues: trademark, trade dress, false advertising, platform terms of service, contract rights against the AI vendor, unfair competition, and trade secret theories are not analyzed here. No conclusion below should be read as addressing those separate doctrines. The two facts most likely to change the answer are: first, the actual degree of human control reflected in the source files and editing history; second, whether the competitor reused the same output or only created a different image with a similar theme or aesthetic. The analysis below is therefore conditional. ([Kantor Paten dan Merek AS][2]) ## III. FACT PLATFORM Confirmed facts A startup used text prompts and minor Photoshop edits to create ad images, then sent DMCA takedowns against competitors said to be reusing similar visuals. Assumed facts For purposes of this memo, I assume the images are U.S. works, the challenged images are visual marketing assets rather than a broader human-authored campaign package, and the described Photoshop work was limited rather than extensive repainting, recompositing, or original illustration. Missing facts Missing facts include whether the startup registered any work with the Copyright Office, how any application described or disclaimed AI-generated material, what the layered source files show, whether the final ads include additional human-authored text/layout/logo/product arrangement, whether the competitors copied identical files or only similar concepts, and what platform(s) received the DMCA notices. Disputed or unstable facts The phrase “minor Photoshop edits” is outcome-sensitive and legally unstable. Minor cleanup may be too slight to create new authorship, while substantial compositing, masking, repainting, or creative arrangement may support a narrower copyright claim. Because the record is incomplete, the analysis is conditional. ([Kantor Paten dan Merek AS][2]) ## IV. APPLICABLE LAW AND AUTHORITY LADDER ### Verified Primary Authority 1. D.C. Circuit — Thaler v. Perlmutter, decided March 18, 2025. This is the strongest current appellate authority directly addressing AI authorship. The court held that the Copyright Act requires all eligible work to be authored in the first instance by a human being, while also explaining that the human-authorship rule does not bar protection for works made by or with the assistance of AI so long as the author is a human. This is binding in the D.C. Circuit and highly persuasive elsewhere because it squarely interprets the federal Copyright Act. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) 2. U.S. Copyright Office, 2023 Registration Guidance for Works Containing Material Generated by Artificial Intelligence. This is not judicially binding, but it is the governing administrative guidance for registration practice. It states that when AI determines the expressive elements of output generated from prompts, that material is not the product of human authorship and must be disclaimed; it also states that copyright may extend to sufficiently creative human selection, arrangement, or modification of AI-generated material. This matters directly because the user’s forum includes the Copyright Office. ([Kantor Paten dan Merek AS][2]) 3. U.S. Copyright Office, Copyright and Artificial Intelligence, Part 2: Copyrightability, published January 29, 2025. This official report synthesizes the Office’s position after notice-and-comment study. It states that copyright does not extend to purely AI-generated material or material where there is insufficient human control over the expressive elements; prompts alone do not generally provide sufficient control; and human authors may claim copyright in perceptible human-authored expression, as well as creative selection, coordination, arrangement, or modifications. This is not a statute or case, but it is highly important agency analysis and current official context. ([Kantor Paten dan Merek AS][4]) 4. U.S. Copyright Office Compendium, Third Edition, current administrative manual. The Compendium states that a work must be created by a human being and that works lacking human authorship are not copyrightable. It is administrative, not binding on courts, but it is the Office’s operative examination manual and therefore significant for any registration-related question. ([Kantor Paten dan Merek AS][5]) 5. 17 U.S.C. § 512 and Supreme Court / appellate procedure authorities. Section 512(c)(3)(A)(v) requires a DMCA notice to include a statement of good-faith belief that the challenged use is not authorized by the copyright owner, its agent, or the law. Section 512(f) creates liability for knowingly materially misrepresenting infringement. Section 512(g) governs counter-notice restoration procedures. These provisions matter because the startup already sent takedowns. ([GovInfo][3]) 6. Supreme Court — Fourth Estate. This case confirms that, for U.S. works, a copyright claimant generally may not commence an infringement suit until the Copyright Office registers the claim or refuses registration. That is a procedural and remedial limitation, not a rule about existence of copyright, but it materially affects leverage if the dispute moves from platform notices to federal court. ([Mahkamah Agung Amerika Serikat][6]) ### Verified Secondary Context 1. Copyright Office Review Board — Théâtre D’opéra Spatial. The Review Board applied the Office’s AI guidance to a visual work and reiterated that human-authored modifications may be protectable, but only if the claim is limited appropriately and does not improperly sweep in AI-generated material. This is not controlling court precedent, but it is useful, current agency application in a visual-art context close to the facts here. ([Kantor Paten dan Merek AS][7]) 2. Ninth Circuit — Lenz v. Universal Music. Lenz is not nationwide controlling law, but it is important persuasive authority on DMCA takedown risk. It holds that fair use must be considered before sending a takedown and reiterates that the Ninth Circuit reads the DMCA’s good-faith requirement subjectively, with § 512(f) liability only for knowing misrepresentation rather than mere unreasonable mistake. ([cdn.ca9.uscourts.gov][8]) 3. Ninth Circuit — Rentmeester v. Nike. This is persuasive, not universal, but helpful on scope. It explains that what copyright protects in a photograph is the author’s selection and arrangement of otherwise unprotected elements, not the underlying elements standing alone. That framework is relevant when a claimant tries to stop “similar visuals” rather than literal copying. ([cdn.ca9.uscourts.gov][9]) ### Unverified / Needs Confirmation Needs confirmation on this record: whether the startup obtained any registration; whether AI-generated material was disclosed and disclaimed; the extent of post-generation human modification; whether the challenged competitor image is pixel-identical, near-identical, or only conceptually similar; and which federal circuit would hear any resulting suit. Those facts could materially change both ownership analysis and DMCA-risk analysis. ### Current-Status Verification Flag Current primary-source verification was available and performed in this session using official Copyright Office materials, official U.S. Code / govinfo materials, the U.S. Supreme Court, and the D.C. and Ninth Circuits. Even so, this remains a fast-moving area, and the most fact-sensitive question is not the abstract rule but whether the actual workflow shows enough human control and originality to support a nontrivial claim. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) ## V. MULTI-BRANCH ANALYSIS ### Branch A — strongest route to outcome one The startup’s best argument is not that the AI output itself is fully protected, but that the final marketing asset contains protectable human authorship layered on top of AI-generated material. Current Copyright Office guidance expressly allows protection where a human selects or arranges AI-generated material in a sufficiently creative way, or modifies AI-generated material to a degree that itself meets the originality threshold. The 2025 Copyright Office report makes the same point and adds that protection may reach perceptible human-authored expression and the creative selection, coordination, and arrangement of human-authored and AI-generated material, even though it does not extend to the AI-generated elements standing alone. ([Kantor Paten dan Merek AS][2]) On that theory, a company could have a real but narrow copyright claim if its ad asset is more than a raw AI image — for example, if the human author chose and placed multiple visual elements, overlaid original copy, set composition, cropped and masked creatively, added original graphic features, or materially repainted or reworked the image. In that circumstance, the better framing is a claim to the human-authored final arrangement or modified version, not a claim that the model-generated pixels as such belong to the company. The D.C. Circuit’s Thaler decision is consistent with that narrower position because it rejects nonhuman authorship while expressly noting that works made by or with AI assistance can be protected where the author is a human being. ([Kantor Paten dan Merek AS][2]) If the competitor reused the same finished ad asset, or a near-identical reproduction of the startup’s human-authored arrangement, the startup’s enforcement position improves. Rentmeester supports the general proposition that copyright may cover the particular selection and arrangement of elements even where the underlying elements are individually unprotected. So, if the competitor copied the startup’s exact expression rather than merely its premise, that is the best path to a defensible infringement claim. ([cdn.ca9.uscourts.gov][9]) ### Branch B — strongest route to outcome two The stronger path on the present facts is that the startup cannot claim broad copyright protection in the images themselves. The Office’s 2023 guidance says that where a user supplies only a prompt and the AI determines the traditional expressive elements, the output is not the product of human authorship. The 2025 Office report goes further and states that, given currently available technology, prompts alone do not provide sufficient human control to make the user the author of the output. The D.C. Circuit’s 2025 opinion reinforces the core statutory premise: copyrightable work must be authored in the first instance by a human being. ([Kantor Paten dan Merek AS][2]) On the facts given, “text prompts and minor Photoshop edits” is the weak formulation for the startup. The Office’s framework turns on human creative control and whether the human actually formed the traditional elements of authorship. That means minor touchups, cleanup, or mechanical finishing steps may be too insubstantial to convert an AI-directed image into a protected human-authored work. That conclusion is an inference from the current authorities, not a categorical rule, but it is the most likely inference from the present record. ([Kantor Paten dan Merek AS][2]) Even if some limited copyright exists, the startup still faces a scope problem. Copyright does not automatically give the owner a monopoly over the ad’s general concept, aesthetic direction, or the unprotected ideas conveyed by prompts. Rentmeester frames the relevant limit well: protection attaches to the author’s particular selection and arrangement, not the individual building blocks standing alone. So if competitors are using “similar visuals” rather than copying the same final expression, infringement becomes substantially harder to prove. ([Kantor Paten dan Merek AS][4]) ### Branch C — strongest threshold, procedural, or remedial complication The first procedural complication is registration. Even if the startup has a valid copyright in some human-authored aspects of the final ad, a federal infringement suit over a U.S. work generally cannot be instituted until the Copyright Office registers the claim or refuses registration. So a business that has only sent DMCA notices but has not sorted out registration posture may have platform leverage but weaker litigation readiness. ([Mahkamah Agung Amerika Serikat][6]) The second complication is DMCA exposure. A takedown notice must assert a good-faith belief that the use is not authorized by the owner, its agent, or the law, and § 512(f) imposes liability for knowing material misrepresentation. If a company sends notices claiming ownership of the whole AI-generated image while its actual protectable authorship is minimal or unclear, that creates some risk — especially if the target counters that the use is noninfringing because it copied only unprotectable AI-generated material or only a similar concept. Still, § 512(f) is not easy to win: Lenz, relying on Rossi, emphasizes that in the Ninth Circuit the good-faith standard is subjective and liability requires actual knowing misrepresentation, not mere negligence or overconfidence. ([GovInfo][3]) The third complication is the put-back process. If the alleged infringer sends a valid counter-notification, the service provider generally restores the material within 10 to 14 business days unless the claimant files suit seeking to restrain the allegedly infringing activity. That means overaggressive DMCA use can force an early litigation-or-retreat decision. ([GovInfo][3]) ### Synthesis — most likely predictive result The most likely predictive result is that the startup cannot safely claim copyright in the AI-generated image as a whole based only on prompt-writing plus minor Photoshop edits. At best, the startup may own a narrower and possibly thin copyright in human-authored modifications or in the creative arrangement of the final ad package, and that narrower claim is materially different from claiming ownership over the underlying AI-rendered visual output itself. Because the fact pattern says the startup targeted competitors using “similar visuals,” not necessarily the same final asset, the startup’s substantive infringement position appears weaker than its takedown posture suggests. The decisive rule is the human-authorship requirement; the decisive fact is whether the human contribution actually determined protectable expression rather than merely supplied prompts and slight cleanup. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) ## VI. COUNTERARGUMENTS AND FRAGILITY POINTS 1. Opposing position: prompt engineering plus iterative refinement should count as authorship. Why it is not frivolous: prompts can encode detailed creative intent, and technology may increasingly allow tighter user control. Legal strength: medium. Best limiting response: the current official position is that, with generally available tools today, prompts alone do not provide sufficient human control over the expressive elements, even when detailed and iterated. What additional fact or authority would sharpen the answer: evidence that the tool allowed deterministic, element-level control rather than probabilistic generation. ([Kantor Paten dan Merek AS][4]) 2. Opposing position: even if the AI-generated pixels are not protected, the startup’s Photoshop work and ad assembly create a protectable derivative or compilation work. Why it is not frivolous: the Office expressly recognizes protection for sufficiently creative modification and arrangement of AI-generated material. Legal strength: medium. Best limiting response: that argument succeeds only if the edits are materially original; “minor Photoshop edits” may not clear that threshold, and the claim would still reach only the human-authored contribution, not the AI material standing alone. What additional fact or authority would sharpen the answer: layered files, edit history, and a precise authorship statement from any registration. ([Kantor Paten dan Merek AS][2]) 3. Opposing position: even thin rights are enough if the competitor copied the exact finished image. Why it is not frivolous: copyright can protect the author’s specific arrangement or modified final expression, and exact reuse is far easier to show than conceptual similarity. Legal strength: strong if the copying was literal or near-literal; weak to medium if the copying was only thematic. Best limiting response: the current fact pattern says “similar visuals,” which suggests a scope problem unless there is evidence of actual duplication of the startup’s protected final expression. What additional fact or authority would sharpen the answer: side-by-side comparison, metadata, and platform upload history. ([cdn.ca9.uscourts.gov][9]) 4. Opposing position: DMCA misrepresentation exposure is overstated because § 512(f) requires more than a bad legal position. Why it is not frivolous: the statute requires a knowing material misrepresentation, and Lenz/Rossi read the good-faith requirement subjectively. Legal strength: strong. Best limiting response: that is correct as a litigation-risk matter, but the business risk remains real because weak takedowns can trigger counter-notices, platform pushback, fee burn, and discovery into what the company actually believed about ownership. What additional fact or authority would sharpen the answer: internal communications, prior legal review, and the circuit where any § 512(f) claim would be filed. ([GovInfo][3]) ## VII. OUTCOME CALIBRATION AND NEXT-STEP GUIDANCE Predicted outcome: on the facts given, the startup likely cannot sustain a broad claim that the AI-heavy ad images themselves are protected as company-owned copyrighted works. The better view is that any valid copyright, if it exists at all, is limited to sufficiently original human-authored edits or arrangement. A DMCA campaign aimed at merely “similar” visuals is therefore materially more fragile than a campaign aimed at exact copying of a human-authored final composite. ([Kantor Paten dan Merek AS][2]) Confidence level: Medium. Reasons for the confidence rating: the governing human-authorship rule is now quite clear in current official sources, and the Office has been consistent that prompts alone generally are not enough. What keeps confidence below high is that the key application question is intensely factual: “minor Photoshop edits” could range from trivial cleanup to meaningful protectable modification, and the phrase “similar visuals” is too vague to assess copying of protectable expression. ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) What could change the answer: a registration certificate that properly disclaims AI material while claiming original human selection/arrangement; source files showing substantial human repainting or compositing; proof the competitor reused the exact final asset; or a forum-specific precedent strengthening or weakening DMCA misrepresentation exposure. ([Kantor Paten dan Merek AS][2]) What must be verified next: 1. Whether any Copyright Office application or registration exists, and exactly how authorship and exclusions were described. 2. The layered source files showing the extent of human editing. 3. Whether the competitor copied the same file, a near-identical final arrangement, or only a similar idea. 4. Which federal circuit would govern any suit or § 512(f) counterclaim. 5. What each DMCA notice actually represented about ownership and infringement. ([Kantor Paten dan Merek AS][2]) Practical informational next step for the recipient: before sending further takedowns, prepare a claim map that separates AI-generated material from human-authored contributions, then compare only those human-authored contributions against the competitor’s asset. That is the cleanest way to decide whether to narrow future notices, pursue registration, or stand down. ([Kantor Paten dan Merek AS][2]) ## VIII. AUDIENCE-TAILORED FINAL SECTION ### PLAIN-ENGLISH SUMMARY Under current U.S. copyright rules, a company usually cannot claim ownership of an image just because its team wrote prompts and got an AI tool to generate it. The law is looking for human-created expression, not just human direction at a high level. That means your startup may have rights only in the parts people actually created themselves, such as meaningful edits, compositing, layout, or other original finishing work. ([Kantor Paten dan Merek AS][4]) In real business terms, that makes a big difference. If a competitor reused the exact same finished ad image, you may have an argument. But if the competitor only made something that looks broadly similar, your position is much weaker, because similarity in concept is not the same as copying protectable human-authored expression. ([cdn.ca9.uscourts.gov][9]) The biggest remaining risk is not just losing the copyright argument later. It is sending strong DMCA notices before you have mapped what, exactly, the company owns. Weak or overbroad notices can trigger counter-notices, force a quick sue-or-retreat decision, and in some circumstances create misrepresentation risk, even though those claims are not easy for the other side to win. ([GovInfo][3]) ## Annex A — Authority Verification Ledger 1. Source type: federal appellate decision Authority name: Thaler v. Perlmutter, D.C. Circuit, March 18, 2025 Level of control: binding in D.C. Circuit; highly persuasive elsewhere Proposition supported: the Copyright Act requires human authorship; AI-assisted works may still be protected if the author is human Verification status: verified from official court opinion ([Pengadilan Banding AS untuk Sirkuit D.C.][1]) 2. Source type: agency registration guidance Authority name: U.S. Copyright Office, Works Containing Material Generated by Artificial Intelligence, March 2023 Level of control: governing registration guidance for the Office; persuasive in court Proposition supported: prompts alone generally do not make the user the author; human selection, arrangement, or substantial modification may be protected; AI-generated material more than de minimis should be disclosed and excluded Verification status: verified from official Copyright Office guidance ([Kantor Paten dan Merek AS][2]) 3. Source type: agency report Authority name: U.S. Copyright Office, Copyright and Artificial Intelligence, Part 2: Copyrightability, January 2025 Level of control: official agency analysis; persuasive, not binding Proposition supported: prompts alone generally insufficient; insufficient human control defeats protection; perceptible human expression and creative arrangement/modification can be protected Verification status: verified from official Copyright Office report ([Kantor Paten dan Merek AS][4]) 4. Source type: agency manual Authority name: Compendium of U.S. Copyright Office Practices, Third Edition Level of control: internal administrative manual; persuasive context Proposition supported: works must be created by a human being; works lacking human authorship are not copyrightable Verification status: verified from official Compendium text ([Kantor Paten dan Merek AS][5]) 5. Source type: statutory text Authority name: 17 U.S.C. § 512 Level of control: binding federal statute Proposition supported: takedown notices require a good-faith statement; knowing material misrepresentation creates damages exposure; counter-notice process can lead to put-back Verification status: verified from official U.S. Code / govinfo text ([GovInfo][3]) 6. Source type: Supreme Court decision Authority name: Fourth Estate Pub. Benefit Corp. v. Wall-Street.com, LLC Level of control: binding nationwide Proposition supported: registration generally must occur before a U.S. copyright infringement suit is filed Verification status: verified from official Supreme Court opinion ([Mahkamah Agung Amerika Serikat][6]) 7. Source type: Copyright Office Review Board decision Authority name: Théâtre D’opéra Spatial review decision, September 2023 Level of control: persuasive administrative application Proposition supported: visual works containing AI material may include protectable human modifications, but claims must be limited and not sweep in AI-generated material Verification status: verified from official Copyright Office Review Board letter ([Kantor Paten dan Merek AS][7]) 8. Source type: federal appellate decision Authority name: Lenz v. Universal Music Corp., Ninth Circuit Level of control: binding in Ninth Circuit; persuasive elsewhere Proposition supported: fair use must be considered in DMCA takedowns; § 512(f) requires knowing misrepresentation and uses a subjective good-faith framework in that circuit Verification status: verified from official Ninth Circuit opinion ([cdn.ca9.uscourts.gov][8]) 9. Source type: federal appellate decision Authority name: Rentmeester v. Nike, Ninth Circuit Level of control: persuasive outside Ninth Circuit Proposition supported: copyright in visual works may be limited to the particular selection and arrangement of otherwise unprotected elements Verification status: verified from official Ninth Circuit opinion ([cdn.ca9.uscourts.gov][9]) ## Annex B — Risk / Remedy / Exposure Matrix Item 1 Issue: ownership of the AI-heavy image itself Best-case outcome: only the human-authored modifications or arrangement are recognized as protected Worst-case outcome: no meaningful copyright in the image component at all Procedural risk: registration or application description may fail to separate AI material from human authorship Remedy exposure: weak ability to sustain infringement claims over “similar” images Confidence note: medium-high that prompts plus minor edits alone are not enough for a broad claim ([Kantor Paten dan Merek AS][2]) Item 2 Issue: scope of infringement claim against competitors Best-case outcome: claim survives if the competitor copied the exact final composite or the same protectable arrangement Worst-case outcome: claim fails because the competitor copied only unprotectable AI-generated material or only a similar concept Procedural risk: expensive factual comparison and expert-style parsing of protectable versus unprotectable elements Remedy exposure: narrowed injunction prospects and weaker settlement leverage Confidence note: medium because scope turns on side-by-side similarity to protected human expression, not general likeness ([cdn.ca9.uscourts.gov][9]) Item 3 Issue: DMCA takedown posture Best-case outcome: notices stand if the company had a defensible, good-faith view that the competitor copied protectable material Worst-case outcome: counter-notices arrive, content is restored, and the company is pressured to sue or retreat Procedural risk: § 512(g) put-back timeline and § 512(f) allegations Remedy exposure: damages and fees are possible under § 512(f), though not easy to obtain Confidence note: medium; practical platform risk is real even where ultimate § 512(f) liability remains hard to prove ([GovInfo][3]) Item 4 Issue: readiness for federal litigation Best-case outcome: a properly framed registration supports suit over clearly human-authored elements Worst-case outcome: no registration, or a registration posture inconsistent with the company’s DMCA ownership theory Procedural risk: suit may be barred until registration or refusal; ownership theory may narrow during Office review Remedy exposure: delay, motion practice, and reduced leverage Confidence note: high that registration posture matters materially before federal enforcement ([Mahkamah Agung Amerika Serikat][6]) Kalau kamu mau, aku bisa lanjutkan versi kedua yang lebih “client-ready” lagi, misalnya dibuat lebih ringkas seperti memo untuk founder atau dibuat jadi format argument map one-page. [1]: https://media.cadc.uscourts.gov/opinions/docs/2025/03/23-5233.pdf "https://media.cadc.uscourts.gov/opinions/docs/2025/03/23-5233.pdf" [2]: https://www.copyright.gov/ai/ai_policy_guidance.pdf "https://www.copyright.gov/ai/ai_policy_guidance.pdf" [3]: https://www.govinfo.gov/content/pkg/USCODE-2011-title17/pdf/USCODE-2011-title17-chap5-sec512.pdf "https://www.govinfo.gov/content/pkg/USCODE-2011-title17/pdf/USCODE-2011-title17-chap5-sec512.pdf" [4]: https://www.copyright.gov/ai/Copyright-and-Artificial-Intelligence-Part-2-Copyrightability-Report.pdf "https://www.copyright.gov/ai/Copyright-and-Artificial-Intelligence-Part-2-Copyrightability-Report.pdf" [5]: https://www.copyright.gov/comp3/chap300/ch300-copyrightable-authorship.pdf "https://www.copyright.gov/comp3/chap300/ch300-copyrightable-authorship.pdf" [6]: https://www.supremecourt.gov/opinions/18pdf/17-571_e29f.pdf "https://www.supremecourt.gov/opinions/18pdf/17-571_e29f.pdf" [7]: https://www.copyright.gov/rulings-filings/review-board/docs/Theatre-Dopera-Spatial.pdf "https://www.copyright.gov/rulings-filings/review-board/docs/Theatre-Dopera-Spatial.pdf" [8]: https://cdn.ca9.uscourts.gov/datastore/opinions/2015/09/14/13-16106.pdf "https://cdn.ca9.uscourts.gov/datastore/opinions/2015/09/14/13-16106.pdf" [9]: https://cdn.ca9.uscourts.gov/datastore/opinions/2018/02/27/15-35509.pdf "https://cdn.ca9.uscourts.gov/datastore/opinions/2018/02/27/15-35509.pdf"