A Comparative Study of the Copyright Laws for Artificial Intelligence in the UK and Korea

Abstract

In the new paradigm in which artificial intelligence plays a critical role in operating a social and technological system, copyright laws have a lot of legal issues. In this paper, the copyright laws of two countries (the UK and Korea) are compared to distinguish the characteristics of major developed and emerging countries. In general, whereas major developed countries such as the US and the UK are favourable to the protection of new technology, emerging and developing countries have tried to lower the level of regulation of new technology in order to promote the business related to the new paradigm. In the case of artificial intelligence, the UK has a legal system that can cover work created by means of artificial intelligence, in contrast, Korea has no copyright law on artificial intelligence, including computer-generated work. Thus, the emerging countries have mitigated the regulations on copyright in order to support the catch-up strategies of their companies. The copyright law on artificial intelligence in emerging and developing countries needs to be designed for fair competition and fair trade. In addition, the duration of protecting work created by means of artificial intelligence should be shortened, because artificial intelligence can produce a lot of work in a very short time. This paper compared several case laws to compare the cases of copyrights related to artificial intelligence or computer-generated works.