RETROSPECTIVE RECORD · PREPARED 16 SEPTEMBER 2026The ledger archive · 100 retrospective records ↗
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A comic's text kept copyright while its AI images lost it

The Copyright Office's own letter explains why Zarya of the Dawn's images and text were treated differently.

Historical event
February 21, 2023
First source published
February 21, 2023
Site publication
September 18, 2026
Visual for this record: A comic's text kept copyright while its AI images lost it
Visual published by masslawblog.com, shown for identification of the record. Credit: masslawblog.com · source page ↗ Rights: owner-review-pending. Source

The record

On 21 February 2023, the United States Copyright Office sent a letter to counsel for Kristina Kashtanova concluding its review of the registration for her comic book Zarya of the Dawn. The letter recounts that Kashtanova had registered the eighteen-page work on 15 September 2022 without disclosing that its images were generated using the Midjourney artificial intelligence tool, that the Office learned of this through social media statements shortly afterward, and that it wrote to Kashtanova on 28 October 2022 seeking an explanation, receiving a response from her attorney on 21 November 2022. The February letter states the Office's conclusion: it would cancel the original certificate and issue a new one covering only the material it found to reflect human authorship.

What the documents show

The letter draws a specific line rather than a blanket one. It states that Kashtanova is the author of the work's text and of the selection, coordination and arrangement of its written and visual elements, and that this authorship is protected by copyright; it states separately that the individual images Midjourney generated are not the product of human authorship and cannot be registered. The reissued registration, the letter states, would carry the same effective date as the original, 15 September 2022, with the public record updated to note the cancellation. The Office's own AI policy hub, retrieved 16 September 2026, lists this letter among a small set of registration decisions, alongside later Review Board decisions on other AI works, that the Office treats as part of a developing record rather than a single settled rule.

Why it stays interesting

The letter is notable for what it protects as much as what it denies: a curatorial and textual layer of human decision-making survives even where a generative tool supplied the images those decisions arranged. This is editorial: for any author or publisher incorporating AI-generated material into a larger work, the letter suggests that disclosure and a clear account of which elements involved human authorship may determine how much of a finished work can be registered at all, though the letter itself addresses only this one work's specific facts and process.

What to read next

A reader could next check the Copyright Office's Part 2 report on copyrightability, referenced on the same policy hub, which addresses the broader question this individual letter did not need to resolve: how the Office reasons about AI-generated output generally rather than one applicant's specific comic book. A contemporaneous district court ruling on a different AI-authorship question, recorded elsewhere in this ledger, offers a useful contrast in how a court versus the Office each approached human authorship.

The letter settles one applicant's registration, not a general rule for every AI-assisted work, and this entry keeps that distinction as carefully as the Office's own letter does.

Sources & reading trail

States the Office's reasoning, the correspondence timeline, and the decision to reissue a narrower registration.

Source published: 21 February 2023 · Retrieved: 16 September 2026

Lists the Zarya decision among the Office's key AI-related registration decisions, confirming its date within the broader policy context.

Source published: Not established · Retrieved: 16 September 2026

Reports, filings, records and studies establish the entry; the reading of why it stays interesting is Chapter Ledger editorial analysis. This retrospective draft does not imply the site published on the event date.

Continue reading

Sources & reading trail

The documents above establish the record. The reading and the questions are this publication’s editorial analysis, written after the fact.

Published September 18, 2026, not on the date of the event described.