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Искусственный интеллект и произведения машинного творчества: применимость опыта стран общего права к российскому регулированию
The article of graduate students of the National Research University Higher School of Economics A.O.Abyshko (Moscow, aabyshko@hse.ru) and G.S.Sabirov (Moscow, gsabirov@hse.ru) is devoted to approaches of common law countries to the definition of the concept of «artificial intelligence», recognition and distribution of intellectual rights to objects created by artificial intelligence systems are analyzed. The issue is examined in the context of statutory and case law, as well as doctrinal approaches in the United Kingdom, Australia, New Zealand and Singapore. The authors come to the conclusion that it is possible to partially borrow certain approaches of common law countries to the regulation of intellectual property created with the help of artificial intelligence, provided they adapt to the existing order in the Russian Federation. It is proposed to provide protection to works created by artificial intelligence, securing limited rights for holders of exclusive rights to such systems through the introduction in Russia of the institution of related rights of manufacturers of artificial intelligence systems.