Copyright Protection for AI-Generated "Text-to-Image" Works: A Case Study of the "Banxin Case"

DOI: https://doi.org/10.62517/jel.202514533

Author(s)

Yufan Chen

Affiliation(s)

Foreign Language School, Hainan University, Haikou, China

Abstract

The rise of artificial intelligence" text-to-image" technology poses new challenges to the existing copyright protection system. The "Banxin Case," as one of the typical judicial cases in this field, clarifies the central role of human creators in the copyright ownership of AI-generated content. Its core guiding value lies in establishing a human authorship recognition standard centered on "creative labor" and "originality." Case analysis demonstrates that users, through creative efforts such as prompt word design, iterative optimization, and post-generation modifications, play a dominant role in the formation of the work and can thus be recognized as the copyright subject. The court, in its ruling, invoked Article 11 of China's Copyright Law, which states that "the natural person who creates a work is the author," emphasizing that originality must stem from human intellectual labor and aesthetic choices. Furthermore, by defining the technical characteristics of "text-to-image" generation and its differences from traditional works, the judgment argues that AI serves merely as a tool rather than a creative subject. It also elaborates on the jurisprudential reasons why AI cannot be a copyright subject and outlines the conditions for recognizing human creators, namely that the work must reflect originality and be the direct result of intellectual labor.

Keywords

Originality; Copyright Subject; AI Text-to-Image Generation

References

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