Perhaps this, incorporating a quote from the copyright office?

> U.S. Copyright Office tells Judge that AI Artwork "created without any human involvement" is not protectable

alternatively,

> U.S. Copyright Office tells judge it affirms decision to refuse to name the AI as an author of a protected artwork

(when I wrote this, the title on this post was "U.S. copyright office tells judge that AI artwork isn’t protectable" and links to https://petapixel.com/2023/02/09/u-s-copyright-office-tells-...)