Here are 4 variations from an ad featuring a girl wearing shorts and a tied plaid shirt. These look NOTHING like the ad, and thus, can be considered derivative works. And, I do wish Congress would strike down agencies making “rules” and “regulations” that are law-binding. In the case of Ai work, the copyright office has decided (without legislation) that Ai work cannot be copyrighted. I would argue there are reasons it should be allowed.