Now that so much creative material is digital it is possible to have computers generate all the combinations possible. For example an image of size 1000 x 800 pixels has a fixed number of elements (pixels) and there is a limited number of colors that each can take, hence it is possible to generate all images possible in that format - and then (possibly) copyright them. Similarly for text.
A Russian company claims to own the copyright of 97% of the text ever produced by humans.
