Imago Ex Machina: An International Analysis of Copyright in the Era of Generative Artificial Intelligence

This study provides a comprehensive analysis of the profound challenges posed by generative artificial intelligence (AI) to the international copyright framework. The two central legal dilemmas are examined: the protectability of AI-generated images (the "output problem") and the lawfulness of using copyrighted works for training AI models (the "input problem"). Through a comparative legal methodology, the study analyzes the divergent approaches that are emerging in key jurisdictions, including the United States, the European Union (with a detailed focus on Italy), the United Kingdom, China and Japan. The analysis reveals a fragmented global landscape, suspended between the imperative to protect human creativity and the drive to promote technological innovation. It concludes that, while existing legal principles are being challenged, the lack of international consensus necessitates a re-evaluation of the concepts of authorship, originality and fair dealing in the digital age, pointing to a future of hybrid licensing models and evolving legislative frameworks.