806.4 (C) Human Performance Required
The Copyright Act protects “original works of authorship.” 17 U.S.C. § 102 (A). To qualify as a work of authorship, a pantomime must involve “the real pantomime of real men.” Kalem, 222 U.S. at 61-62. Pantomimes performed by animals, robots, machines, or any other animate or inanimate object are not copyrightable and cannot be registered with the U.S. Copyright Office.