Dr. Stephen Thaler, who developed and owns an AI system called Creativity Machine, filed to register outputs generated from the AI system for copyright registration in November 2018. The U.S. Copyright Office (USCO) denied the registration application for the AI-generated work in a final agency action for the lack of “human authorship necessary to support a copyright claim.” Thaler filed against Perlmutter, the register at the USCO, for a judicial review of the denial under the Administrative Procedures Act, claiming that this rejection was contrary to the plain language of the Copyright Act and the statutory purpose of its mandate to promote the progress of science. In granting summary judgment in favor of the USCO, the District Court for the District of Columbia held in August 2023 that human authorship is an essential part of a valid copyright claim, emphasizing that authorship centers on human creativity. Thaler has since filed an appeal to the Court of Appeals for the D.C. Circuit.