Ah, ok. As for testing in court, that will be useful, but a rather official source says "created by a human author" [0] in defining the notion of copyright, which I assume is paraphrasing actual law, which I assume a judge would interpret similarly. However, I will concede that it's conceivable that if a human authors a work that then itself authors another work, the second work could potentially be attributed to the human for purposes of copyright eligibility.
[0] https://www.copyright.gov/what-is-copyright/