Copyright Developments

On March 19, 2025, the District Court for the Central District of California granted Mariah Carey’s motion for summary judgment dismissing a copyright infringement claim brought against her for allegedly copying the holiday hit “All I Want for Christmas Is You.” 

Only humans can be authors under the Copyright Act, the D.C. Circuit Court of Appeals affirmed in a unanimous opinion on March 18, 2025.

The Court considered whether an artificial intelligence model could be an “author” of a work for copyright purposes – and answered “no.” In doing so, however, the court left open the crucial question of whether a human can be the “author” of an AI-generated work where he made and used the AI to generate the work.