Generative AI and the Music Industry: The Emerging Copyright Conundrum in India

Subhajit Basu* & Jui Dharwadkar**

Introduction

The music industry has experienced a significant transformation due to technological advancements. Music production, distribution, and consumption have undergone remarkable changes in this era of rapid innovation.[1] The proliferation of Artificial Intelligence (AI) in music has led to substantial investments in AI-generated compositions.[2] This swift commercialisation of AI music can be attributed to advancements in algorithms, such as generative adversarial networks (GANs), and the vast availability of training data.[3]

​Recent lawsuits filed against OpenAI by prominent labels in the music industry, including T-Series, Saregama, and the Indian Music Industry (IMI),[4] underscore the growing concerns surrounding the unauthorised use of copyrighted music in training artificial intelligence (AI) models. These legal actions highlight the inadequacies of the current Indian legislative framework in effectively addressing AI-related intellectual property rights (IPR) issues.[5] This article aims to critically analyse the shortcomings of the existing IPR framework, set against international policies and jurisprudential literature, and propose amendments to Indian copyright regulations. The objective is to uphold the legal rights of musicians while promoting the ethical development of AI within the music industry.

Understanding GenAI And Its Implications

​Generative Artificial Intelligence (GenAI) utilises models, such as Generative Adversarial Networks (GANs), to generate novel outputs from existing data. A GAN comprises two neural networks—the generator and the discriminator—that engage in a continuous adversarial process to enhance their respective functions. The generator learns the probabilistic distribution of the training data to create new data samples that closely mimic real data. Concurrently, the discriminator evaluates these samples to determine whether they are real or artificially generated. This dynamic interplay persists until the artificial data becomes indistinguishable from authentic data, a process known as adversarial training. GANs have been instrumental in advancing the field of machine learning, particularly in tasks involving image and audio synthesis.[6]

​Using pre-existing works as training data in computational processes raises significant concerns regarding potential copyright infringement. Specifically, algorithms trained on input data without duly considering the intellectual property rights of the original creators may violate these rights. This issue is particularly pertinent in GenAI, involving multiple stakeholders—from companies developing the algorithmic models to those fine-tuning them for specific tasks and end-users who further adapt the models through specific prompts.[7] Such a multifaceted ecosystem presents complex challenges in determining the authorship and ownership of AI-generated works.[8]

The current copyright framework in India does not explicitly address the nuances associated with AI-generated content. The Copyright Act of 1957, which governs intellectual property rights in the country, lacks provisions that directly pertain to works produced by AI systems. This legislative gap has led to legal disputes, such as the lawsuit filed by Asian News International (ANI) against OpenAI in November 2024.[9] ANI alleged that OpenAI utilised its copyrighted content without authorisation to train AI models, highlighting the pressing need for a legal framework that can effectively navigate the complexities introduced by AI technologies. Furthermore, the involvement of multiple agents in the GenAI pipeline complicates the attribution of authorship and the assignment of rights. Determining liability and ownership becomes challenging when multiple entities contribute to the development and deployment of AI models. The absence of clear legal guidelines in this domain highlights the need for a comprehensive examination of the existing Indian copyright framework.

The Growing Integration Of GenAI In The Music Industry

In recent years, GenAI has become an integral component in the composition and consumption of music in the digital age. According to the IFPI Global Music Report 2025, GenAI is poised to become a transformative force in music creation, indicating its inevitable integration into the industry’s production system.[10] This accelerating integration is already evident in contemporary practices. For instance, an Indian composer recently utilised AI to recreate the voices of two deceased vocalists for an upcoming feature film. Similarly, in the Telugu motion picture Hi Nanna, AI technology was expressly acknowledged when the composer employed Musicfy—an AI voice-generation platform—to enhance the original song. The proliferation of such platforms is also apparent in the emergence of homegrown initiatives. Beatoven.ai, an Indian musical AI start-up, has distinguished itself as the country's first original song-generation platform to receive certification as a fairly and ethically trained AI model,[11] having developed its proprietary music database. This evolution in the application of AI technologies signals a significant shift in the underlying intent behind what would traditionally be characterised as copyright infringement. Increasingly, the focus is on achieving a balance between protecting original creative works and fostering innovation—underpinned by appropriate accreditation and fair compensation.

However, the widespread popularity of GenAI technologies has also sparked considerable concern regarding the use of unlicensed, copyrighted works to train these models. In 2024, over two hundred music artists voiced concerns about the irresponsible deployment of AI to undermine the rights of human artists to fair remuneration and creative recognition.[12] This protest was triggered by incidents of AI-generated voice cloning of original songs, which were subsequently disseminated on major music streaming platforms, including Spotify and Apple Music. In a striking demonstration of discontent, over a thousand musicians recently released a silent album to protest the UK government's proposed reforms to copyright law—reforms that would permit AI companies to train their models on copyrighted content without securing licenses.[13] Such concerns have also resonated within the Indian music industry. Prominent singers and musicians, including Kumar Sanu and Shaan, have publicly expressed apprehension over AI systems' unauthorised use of their voices and are actively exploring legal avenues to safeguard their vocal identities.[14]

Indian Copyright Framework and GenAI

The Indian Copyright Act, 1957 ("the Act") does not explicitly recognise works generated with the assistance of Artificial Intelligence (AI). The Act prohibits copying, save where such use falls within the statutory exception of "fair dealing."[15] Notably, the term "fair dealing" is nowhere defined within the Act. However, judicial pronouncements have established three guiding factors to determine whether a particular use constitutes fair dealing: the quantity and value of the portion used, the purpose for which it is employed, and the potential market competition between the original and the derived work.[16]

As previously mentioned, the case of Asian News International (ANI) v. OpenAI marks the first instance in which an Indian court will adjudicate copyright infringement claims involving GenAI. Significantly, the Indian Music Industry (IMI) has sought to intervene in the proceedings, filing an application that raises concerns regarding the unauthorised use of copyrighted musical works in AI training without proper attribution or remuneration. The IMI contends that such practices inflict considerable economic harm upon the music industry, which derives a substantial portion of its revenue from licensing arrangements. In its defence, OpenAI has argued that its models are trained to create original content and that the copyright law protects only the expression of ideas, not the ideas themselves. The defendants have further invoked the fair dealing doctrine, maintaining that the training data in question consists of publicly accessible materials sourced from a wide array of platforms. The IMI, in response, has rebutted this defence, asserting that the unauthorised use of copyrighted content for training purposes directly undermines the economic and moral rights of copyright holders. While the matter remains pending before Indian courts, it will be instructive to observe how courts assess these competing claims within the established framework of copyright law.

Beyond questions of infringement, Indian copyright jurisprudence now confronts a deeper structural challenge: whether works generated by AI can attract copyright protection, and if so, under what conditions. The definition of "author"[17] under the Act is confined to natural persons, thereby excluding AI-generated works from copyright eligibility. Indian courts have, to date, consistently upheld the principle of human authorship as a prerequisite for copyright protection.[18] Nevertheless, recent developments suggest a potential shift in this orthodox position. A notable example is the case involving an artwork entitled Suryast, created by an AI model named RAGHAV. The Indian Copyright Office initially declined to register the work because it lacked human authorship. However, registration was eventually granted when the programmer of RAGHAV was designated as a co-author. While this approach has yet to receive judicial endorsement, it signals an emergent recognition of the evolving relationship between human creativity and machine-generated outputs.

This evolving dynamic carries broader implications for questions of authorship, ownership, and accountability in relation to AI-generated works. It raises fundamental questions about whether the current legal framework is fit for its purpose in an era characterised by algorithmic creativity. Against this backdrop, the emerging jurisprudence surrounding AI and copyright provides an opportunity to re-evaluate the conceptual foundations of Indian copyright law and consider whether legislative reform is warranted to address the novel challenges that AI technologies pose.[19]

Comparative Developments: China

The earliest case regarding the status of works generated with AI assistance in China was heard by the Beijing Internet Court in 2018, wherein the Court upheld a copyright-protectable interest in a work partially generated by software.[20] A subsequent lawsuit further clarified this ambiguity. Despite claims of lack of human authorship in an article written by the plaintiff's Dreamwriter AI, a Shenzhen district Court granted copyright protection because the article exhibited careful selection and analysis, fulfilling the standard of originality.[21] This position was demonstrated when an individual created an image using the AI image generator Stable Diffusion. The Court held that the order and selection of the prompts, the modified parameters, and the decision of which picture is the most suitable reflect an intellectual investment that qualifies under the threshold of originality.[22] Chinese Courts have displayed flexibility, ensuring innovation through a modern adaptation of traditional copyright principles. This was also observed in a recent case, popularly known as the Second Chinese AI Work Copyright case,[23] in which the Court found a legitimate copyrightable interest in a 2D image generated using AI tools.

Further, Chinese Courts have given a broad definition to what constitutes original content. Such an interpretation seeks to protect human-AI collaborative artistic endeavours, giving impetus to evolving forms of artistic expressions that are created with the assistance of AI and related technology. China clarified its judicial stance by enacting the Interim Measures for the Administration of GenAI Services ("GAI Measures")2023 as a precursor to its proposed AI law.[24] The GAI Measures are the country's first comprehensive legislation on GenAI, specifically addressing services accessible to the public. It provides an operational framework to ensure compliance from individuals and organisers who utilise GenAI. This is achieved by mandating specific training data requirements, reinforcing accountability through quality assessments and conducting sample verification.[25] Therefore, judicial activism in China is increasingly influencing the AI and copyright discourse, steering policymaking towards innovation and promotion of artistic expressions amidst emerging technological paradigms.

Comparative Developments: USA

In contrast to many other jurisdictions, the United States has pursued a markedly different trajectory in addressing the intersection of copyright and AI.[26] It has developed the "modicum of creativity" standard, under which copyright protection is afforded to works that demonstrate a minimal degree of originality attributable to the author.[27] Early scholarship and case law tended to uphold copyright protection even in instances where works were generated by machines, predicated on the underlying presumption of human involvement in the creative process.[28] However, the rapid evolution of AI technologies has compelled courts and regulatory authorities in the United States to adopt a more nuanced and dynamic approach to regulation. A notable illustration of this shift is found in the Zarya of the Dawn case.[29] In this instance, the US Copyright Office (USCO) granted copyright protection to textual elements of the work that were authored by a human. However, it expressly refused to extend similar protection to AI-generated images because they lacked the requisite human authorship. This decision reflects emerging judicial recognition of the distinction between human creativity and machine-generated content within the broader copyright framework. Similarly, the USCO denied registration of digitally created images "A Recent Entrance to Paradise" and "Théâtre D'opéra Spatial", citing lack of human authorship.

The USCO has, therefore, set a higher standard for qualifying human-AI work to receive copyright protection. The reluctance of the Copyright Office to deviate from this position was reaffirmed when USCO's Review Board upheld the rejection of "Suryast", mentioned earlier, the artwork created by the AI tool RAGHAV.[30] However, a recent notification issued by the USCO has brought respite. The notice has clarified that hundreds of AI-generated works have been granted copyright where sufficient human authorship could be established.[31]The past few years have witnessed dozens of copyright lawsuits against AI companies,[32] particularly from the creative industry, alleging unlicensed use of copyrighted works in AI training. AI companies have defended themselves, often relying on the "fair use" doctrine, which allows for unlicensed use of copyrighted works under certain circumstances like academic research, parody and news reporting.[33] In determining whether a particular work constitutes fair use, the Copyright Act of 1976 enumerates four factors to be considered: (1) the purpose and character of the use, (2) the nature of the copyrighted work, (3) the amount and substantiality of the portion used with regard to the copyrighted work as a whole, and (4) the effect of the use for or value of the copyrighted work as a whole.[34] The first[35] and fourth[36] factors are more significantly relied upon than others.

Fair use, under United States law, has been interpreted with broader scope, grounded in a nuanced application of the four-factor test that seeks to balance competing economic interests[37]. In contrast, the fair dealing doctrine in other jurisdictions, including India, has been predominantly construed within the framework of public interest[38]. Indian copyright law, however, remains inadequately equipped to address the complexities posed by AI-generated content. It lacks a coherent framework for assessing the extent to which the use of copied material amounts to misappropriation—an essential inquiry in determining copyright infringement in the context of AI. Although Indian courts have occasionally drawn upon the U.S. fair use factors for interpretative guidance, the statutory limitation posed by the narrow definition of "fair dealing" significantly restricts judicial flexibility, particularly at the evolving intersection of copyright law and AI[39].

A recent decision by a Delaware Court regarding the use of copyrighted text in AI training has shed new light on the fair use defence claimed by AI companies. The Court granted a summary judgment on fair use on four grounds. It placed heavy reliance on the first and last factors and held that the defence of fair use is insufficient to justify training the AI on copyrighted content. [40] 

The Court was keen to emphasise that this was not a case regarding generative AI. Nevertheless, this verdict holds immense significance for the ongoing spate of GenAI-related copyright infringement cases pending before the courts, particularly if those courts were to apply similar reasoning, especially regarding intermediate copying within the context of the first factor of fair use analysis. Although it is too early to tell, given the diverse technologies involved, the claimants in such cases would likely be reassured by the Court's decision, and it will be interesting to see whether it precipitates a greater number of settlements or shifts in the defendants' positions. 

Despite these developments, the second part of the USCO's report on Copyrightability and AI has enumerated that existing copyright laws are sufficient to address the challenges posed by emerging technologies.[41] Given the conflicting trajectories adopted by courts and the legislative body in the United States, the burden of preserving and cultivating creative expression falls principally on the judiciary’s future chosen course in a dynamically changing, tech-driven era. 

Conclusion

As courts across the globe grapple with copyright infringement claims arising from the use of GenAI, particularly within the music industry,[42] it becomes increasingly imperative to adapt legal frameworks to the realities of the technological revolution.[43]  Innovation constitutes the foundation of an advanced creative ecosystem, fostering economic development and cultural enrichment[44]. Yet, as AI continues to evolve into a transformative tool in the production of art and music, striking an appropriate balance between fostering innovation and safeguarding intellectual property rights becomes ever more critical. This balance, however, is a delicate one and must be navigated with caution and foresight.Two principal concerns emerge at the intersection of AI, copyright law, and judicial adjudication. First, the unauthorised use of copyrighted content as training data for AI models raises complex questions of copyright infringement. Second, the question of whether works generated autonomously or semi-autonomously by GenAI can or should attract copyright protection.

India, while making considerable strides in the field of technology, remains at a relatively nascent stage in addressing the legal challenges posed by AI-driven content creation. The twin issues of infringement and authorship are inextricably linked within the current discourse on copyright. A balanced and context-sensitive approach is essential as policymakers contemplate reforms to India's copyright regime. In particular, contemporary discussions must consider the additional complexities introduced by GenAI and adopt more stringent legal safeguards against copyright infringement. This will serve not only to protect the legitimate interests of rights holders but also to encourage ethical innovation and artistic expression in an increasingly automated society. Moreover, legislative reform must avoid granting AI companies unfettered protection or allowing them to circumvent liability under the guise of technological progress. Instead, the law should reflect a calibrated framework that recognises the value of human creativity, ensures fair attribution and compensation, and holds AI developers accountable for the misuse of copyrighted content.The Indian judiciary now stands at a pivotal moment. The ongoing litigation in ANI v. OpenAI and related interventions presents the courts with a unique opportunity to establish a meaningful precedent—one that could shape the contours of copyright jurisprudence in India for years to come and provide much-needed clarity in an era where the boundaries between human and machine-generated creativity are increasingly blurred.

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*Dr. Subhajit Basu is Professor of Law and Technology, School of Law, University of Leeds, UK

** Jui Dharwadkar is an Independent Scholar

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[1] Xiaorui Guo, ‘The Evolution Of The Music Industry In The Digital Age: From Records To Streaming’ (2023) 5(10) J Soc Ethnol <10.23977/jsoce.2023.051002> accessed 6 April 2025. 

[2] Kristin Robinson, ‘Sony Music Makes First AI Investment, Leading Vermillio’s $16M Series A Funding Round’ (Billboard, 3 March 2025) <https://www.billboard.com/pro/sony-music-ai-investment-vermillio-funding-round/> accessed 6 April 2025; Charlie Fink, ‘Udio Music Raises $10 Million, $6.5 Million For Spines AI, More Sora, Cinematic AI’ (Forbes, 11 April 2024) <https://www.forbes.com/sites/charliefink/2024/04/11/udio-ai-music-raises-10-million-65-million-for-spines-ai-more-sora-cinematic-ai/> accessed 6 April 2025. 

[3] Zongyu Yin, Federico Reuben, Susan Stepney and Tom Collins Yin, ‘Deep Learning’s Shallow Gains: A Comparative Evaluation Of Algorithms For Automatic Music Generation’ (2023) 112 Mach Learn 1785, 1786 <https://doi.org/10.1007/s10994-023-06309-w> accessed 6 April 2025.

[4] Aditya Kalra, ‘Bollywood Music Labels Seek To Challenge OpenAI In India Copyright Lawsuit’ (Reuters, 14 February 2025) <https://www.reuters.com/technology/artificial-intelligence/bollywood-music-labels-seek-challenge-openai-india-copyright-lawsuit-2025-02-14/> accessed 6 April 2025.

[5] Shinu Vig, ‘Intersection Of Generative Artificial Intelligence And Copyright: An Indian Perspective’ (2024) JSPTM <https://doi.org/10.1108/JSTPM-08-2023-0145> accessed 6 April 2025.

[6] Ian Goodfellow, Jonathan Shlens, Christian Szegedy, ‘Explaining And Harnessing Adversarial Examples’ (III International Conference on Learning Representations, San Diego, May 2015).

[7] Carol Mullines Hayes, ‘Generative Artificial Intelligence And Copyright: Both Sides Of The Black Box’ (2023) <http://dx.doi.org/10.2139/ssrn.4517799> accessed 6 April 2025.

[8] Faye F Wang, ‘Copyright Protection for AI-Generated Works: Solutions to Further Challenges from Generative AI’ (2023) 5(1) Amicus Curiae <https://doi.org/10.14296/ac.v5i1.5663> accessed 6 April 2025; Nicola Lucchi, ‘ChatGPT: A Case Study On Copyright Challenges For Generative Artificial Intelligence Systems’ (2024) 15 Eur J Risk Regul 602, 604 <https://doi.org/10.1017/err.2023.59> accessed 6 April 2025; See also Celeste Shen, ‘Fair Use, Licensing, And Authors' Rights In The Age Of Generative Al’ (2024) 22(1) Nw J Tech & Intell Prop 157, 164 <https://scholarlycommons.law.northwestern.edu/njtip/vol22/iss1/4> accessed 6 April 2025.

[9] Dyuti Pandya, ‘The Global South AI Copyright’s Test Case: India’ (Centre for European Policy Analysis, 7 March 2025) <https://cepa.org/article/the-global-south-ai-copyrights-test-case-india/> accessed 6 April 2025. 

[10] International Federation of the Phonographic Industry, ‘Global Music Report 2025’ (IFPI, 19 March 2025) <https://globalmusicreport.ifpi.org/> accessed 6 April 2025. 

[11] ‘Fairly Trained Certified Models: Licensed Model Certification’ (Fairly Trained) <https://www.fairlytrained.org/certified-models> accessed 6 April 2025. 

[12] Liv McMahon, ‘Billie Eilish And Nicki Minaj Want Stop To 'Predatory' Music AI’ (BBC, 2 April 2024) <https://www.bbc.com/news/technology-68717863> accessed 6 April 2025. 

[13] Paul Glynn, ‘Artists Release Silent Album In Protest Against AI Using Their Work’ (BBC, 25 February 2025) <https://www.bbc.com/news/articles/cwyd3r62kp5o> accessed 6 April 2025. 

[14] Yashika Mathur, ‘After Kumar Sanu, Shaan, Arjun Kanungo Speak Up On Legal Protection For Their Voices Against AI Misuse’ (Hindustan Times, 15 July 2024) <https://www.hindustantimes.com/htcity/cinema/after-kumar-sanu-shaan-arjun-kanungo-speak-up-on-legal-protection-for-their-voices-against-ai-misuse-101720791234210.html> accessed 6 April 2025. 

[15] The Copyright Act 1957, s 52 (1)(a).

[16] Civic Chandran v Ammini Amma (1996) 1 KLJ 454.

[17] The Copyright Act 1957, s 2(d).

[18] Rupendra Kashyap v Jiwan Publishing House Pvt Ltd 1994 (28) DRJ 286; Tech Plus Media Pvt Ltd v Jyoti Janda (2014) 60 PTC 121; Navigators Logistics Ltd v Kashif Qureshi & Ors, 254 (2018) DLT 307.

[19] Arjun Padmanabhan and Tanner Wadsworth, ‘A Common Law Theory Of Ownership For AI-Created Properties’(2023) 104 JPTOS <https://ssrn.com/abstract=4411194> accessed 6 April 2025. 

[20] Feilin v Baidu (2018) Jing 0491 Min Chu No. 239.

[21] Shenzhen Tencent Computer System Co Ltd v Shanghai Yingxun Technology Co Ltd No.14010 Minchu (Shenzhen Nanshan District Ct 2019).

[22] Li v Liu (2023) Jing 0491 Min Chu No 11279.

[23] Aaron Wininger, ‘Chinese Court Again Rules AI-Generated Images Are Eligible For Copyright Protection’ (China IP Law Update, 14 March 2025) <https://www.chinaiplawupdate.com/2025/03/chinese-court-again-rules-there-is-copyright-in-ai-generated-images/> accessed 6 April 2025.

[24] ‘Interim Administrative Measures for Generative Artificial Intelligence Services’ (2023) Cybersecurity Administration of China. https://www.china-briefing.com/news/how-to-interpret-chinas-first-effort-to-regulate-generative-ai-measures/

[25] ‘Interim Administrative Measures for Generative Artificial Intelligence Services’ (2023) Cybersecurity Administration of China, art 8.

[26] Andres Guadamuz, ‘Do Androids Dream Of Electric Copyright? Comparative Analysis Of Originality In Artificial Intelligence Generated Works’ (2020) IPQ 2017(2) <https://ssrn.com/abstract=2981304> accessed 6 April 2025. 

[27] Feist Publications Inc v Rural Telephone Service Co (1991) 499 US 340.

[28] Alan Turing, ‘Computing Machinery and Intelligence’ (1950), LIX(236) Mind <https://doi.org/10.1093/mind/LIX.236.433> accessed 6 April 2025; Timothy L Butler, ‘Can a Computer be an Author? Copyright Aspects Of Artificial Intelligence’ (1982) 4 UC Law SF Comm & Ent L J <https://repository.uclawsf.edu/hastings_comm_ent_law_journal/vol4/iss4/11> accessed 6 April 2025.

[29] Zarya of the Dawn (Registration # VAu001480196) (2023).

[30] US Copyright Off Rev Bd, ‘Decision Affirming Refusal to Register SURYAST’ (11 December 2023) <https://www.copyright.gov/rulings-filings/review-board/docs/SURYAST.pdf>; See also Naruto v Stater (2018) 888, where this position was previously developed. The Court, in this case, held that the Copyright Act includes all humanity and necessarily excludes animals.

[31] US Copyright Office, ‘Letter on Artificial Intelligence and Copyright Initiative Update’ (24 February 2024) <https://www.copyright.gov/laws/hearings/USCO-Letter-on-AI-and-Copyright-Initiative-Update-Feb-23-2024.pdf>.

[32] Joseph J Avery and W Michael Schuster, ‘AI Artists On The Stand: Bias Against Artificial Intelligence-Generated Works In Copyright Law’ (2024) UC Irvine Law Review (forthcoming 2025) <http://dx.doi.org/10.2139/ssrn.5082647> accessed 6 April 2025.

[33] In Authors Guild Inc v Google Inc No 13-4829-cv (2d Cir. Oct. 16, 2015), the Court held that scanning digital copies of books for creating an online database constituted fair use. The same doctrine forms the basis of OpenAI’s defence in the ongoing lawsuit, The New York Times Company v Microsoft Corporation 1:23-cv-11195 (SDNY).

[34] 17 US Code § 107.

[35] Campbell v Acuff-Rose Music Inc 510 US 569.

[36] Harper & Row Publishers Inc v Nation Enterprises 471 US 539.

[37] Madison, Michael J. "A pattern-oriented approach to fair use." WM. & MAry l. reV. 45 (2003): 1525.

[38] In Wiley Eastern Ltd v Indian Institute of Management 61 (1996) DLT 281, the Court held that the essential purpose of Section 52 is to preserve the freedom of expression under Article 19(1) of the Indian Constitution.

[39] In The Chancellor Masters and Scholars of the University of Oxford v Narendra Publishing House 2008 (38) PTC 385, the Court adopted the four-factor test under “fair use” to uphold the use of textbooks for academic assistance of students.

[40] Reuters v Ross Case 1:20-cv-00613, ECF 770.

[41] US Copyright Office, ‘Copyright And Artificial Intelligence, Part 2: Copyrightability’ (January 2025) <https://www.copyright.gov/ai/Copyright-and-Artificial-Intelligence-Part-2-Copyrightability-Report.pdf>. 

[42] Concord Music Group Inc et al v Anthropic PBC No 5:24-cv-03811-EKL.                                                                                                                            

[43] Subhajit Basu and Ankeeta Dutt, ‘AI-Generated Art: A Challenge to Creative Integrity?’ (2024) IJLT <https://www.ijlt.in/post/ai-generated-art-a-challenge-to-creative-integrity> accessed 6 April 2025.

[44] Organization for Economic Co-operation & Development, ‘Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report’ (2015) OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris <https://doi.org/10.1787/9789264241046-en>.