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In page Copyright Clause:

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Furthermore, the clause only permits protection of the writings of authors and the discoveries of inventors. Hence, writings may only be protected to the extent that they are original,[4] and "inventions" must be truly inventive and not merely obvious improvements on existing knowledge.[5] The term "writings of authors" appears to exclude non-human authorship such as painting by chimpanzees and computer code written by programmed computers,[6] but the issue has not been tested in litigation.[citation needed]