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96 Univ. Colorado L. Rev. F. 1 (2026)

handle is hein.journals/uvsyocd96 and id is 1 raw text is: ARTIFICIAL ACTORS: AI'S ERASURE OF TALENT Johnathan Khoriaty* If they can do this with actors, they can do it with writers, directors, cinematographers everyone. We'll be replaced with Frankenstein spoonfuls of our own work. - Justine Bateman, Filmmaker.1 From galaxies far, far away to places where no one can hear you scream, for over one hundred years audiences have used films to explore the vast multiverse of possible realities. A cen- tury later, the film industry has used its productions to create almost every world and situation an audience could ever hope to experience. These films have been used to create multiple billion-dollar industries that serve a variety of roles. These in- dustries include production studios, distributors, movie thea- ters, and streaming services, all of whom take massive shares of the revenue that films generate. To a lesser extent, the people involved in the actual making of a film also share part of this revenue, although each receives a much smaller portion of it. This includes directors, producers, editors, and, of course, ac- tors. This share of the revenue is potentially the most vital part of the economics behind Hollywood, as without the individu- als who create the movies themselves the billion-dollar indus- try that Hollywood is could not exist. In 2023, just as the film industry appeared to be recovering from the impacts of the COVID-19 pandemic, tragedy struck again. After months of failed negotiations, the Screen Actors Guild - American Federation of Television and Radio Artists, along with the Writers Guild of America, went on strike, halt- ing the production of most films. Part of the contention during the negotiations for both the actors'and writers'strike was the studios' use of artificial intelligence during the production of * J.D. Candidate, University of Colorado Law School, Class of 2026. Thank you to the University of Colorado Law Review Volume 97 Forum Editorial Staff, Abigail Luetke and Emma Wolters, for leading the effort that made this Note publication- worthy. Additional thanks to my Casenote and Comment Editor, Emma Plante, who guided me through the drafting process, and to David Churchwell, Grace Detwiler, and Professor Blake Reid for their vital feedback on this Note. 1. Todd Spangler, 'This Is an Existential Threat': Will AI Really Eliminate Ac- tors and Ruin Hollywood? Insiders Sound Off VARIETY (Aug. 16, 2023, at 4:28 PM), https://variety.com/2023/digital/features/hollywood-ai-crisis-atificial-intelligence- eliminate-acting-jobs [https://perma.cc/UME9-WM6V] (speaking about artificial in- telligence' recreation of actors).