These comments were submitted to The US Copyright Office via the
notice of inquiry on “on copyright and artificial intelligence (AI).” Ownership around intellectual production is critical to generative activities in academia, industry, and creative
endeavors. As LLMs and other applications of AI transform these processes, we must resolve open questions around ownership and associated rights in ways that reflect diverse stakeholder interests and expertise. We write to encourage clarity of interpretation and
application of existing copyright laws to intellectual products both used as inputs to AI and outputs co-produced by human users and AI collaborators. We look forward to further opportunities to engage with the Agency’s staff to provide additional analysis as the
rulemaking process evolves.