The Copyright Handbook

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The Copyright Handbook Page 17

by Stephen Fishman


  the work is being prepared for commercial

  learned of the infringement.

  distribution and thereby preserve your right

  to obtain statutory damages and attorney

  EXAMPLE: Copyright pirates obtain a

  fees in an infringement suit. You must fol ow

  copy of a draft version of Gil ian Flynn’s

  through with a full registration of the work

  sequel to Gone Girl and release it on

  shortly after publication or infringement

  the Internet before the final version is

  of the work. The fact that a work has

  published. Flynn’s publisher preregistered

  been preregistered does not mean that the

  the book before the draft was stolen. As a

  Copyright Office necessarily will register the

  result, the publisher can immediately file

  CHAPTER 3 | COPYRIGHT REGISTRATION | 87

  work when an application for registration

  Written works other than books may not

  is submitted. Also, you may register an

  be preregistered—for example, a screenplay

  unpublished work without preregistering it.

  not intended to be published in book form.

  The intended commercial distribution of

  Is Preregistration for You?

  the work can be in either physical or digital

  format—for example, e-books or CDs to be

  For the vast majority of works, preregistration sold online.

  is a waste of money. The Copyright Office

  You can’t preregister ideas for new works.

  itself says that “(f)or the vast majority of works, You must have begun to actually write the preregistration is not useful.” Few works,

  work involved, though it does not have to

  especially written works, are infringed upon be finished.

  before they are published or otherwise dis-

  tributed. This type of thing usually occurs

  Online application

  with popular movies and songs. However,

  You preregister by completing an online

  you may benefit by preregistering your work application at the Copyright Office website

  if you think it’s likely someone may infringe (www.copyright.gov). You must provide the

  your unfinished work before it is released.

  following information:

  • the work’s title (a working title may

  How to Preregister

  be used)

  Preregistration is a quick, though expensive,

  • the names of the author and copyright

  process. The whole thing is done online

  claimant

  through the Copyright Office website with

  • the date the actual writing of the book

  no paper involved.

  began and the date you anticipate

  completing it, and

  What can be preregistered?

  • a description of the work—for

  example, whether it is a novel or

  You can preregister your work only if all

  biography, the nature of the subject

  below apply:

  matter, whether it is a later edition or

  • It is unpublished.

  revision of a previous work, and any

  • Its creation has begun.

  other details which may help identify

  • It is being prepared for commercial

  the work in published book form.

  distribution.

  You need not provide the Copyright

  • It is one of the following: a motion

  Office with a copy of your unpublished

  picture, musical work, sound

  work or make any other deposit. The

  recording, computer program, book, or nonrefundable filing fee for preregistration

  advertising photograph.

  is $115.

  88 | THE COPYRIGHT HANDBOOK

  What Is Publication?

  include a preregistration number and date.

  This is the only notice you will receive

  Publication occurs for copyright purposes

  that preregistration has been made. The

  when the copyright owner, or someone

  Copyright Office does not issue a paper

  acting with the copyright owner’s authority,

  certificate of preregistration.

  distributes one or more copies of the work

  to the general public or offers the work

  for distribution, public display, or public

  CAUTION

  performance. Copies do not need to be

  Your preregistration is a public

  sold for publication to occur—they can be

  record. Everything you say in your preregistration

  leased, rented, loaned, or even given away, so

  application becomes a public record of the

  long as the work has been made available to

  Copyright Office that can be read by others. So you

  the general public.

  might not want to say too much about your work-

  Publication does not occur when:

  in-progress. Moreover, if you want to have a website

  • Copies of the work are made but not

  using the book’s title as a domain name, you may

  distributed.

  want to obtain the name before you preregister

  • The text of the work is performed

  the book. Otherwise, a “cybersquatter” could learn

  publicly (for example, a speech is

  about your title from your preregistration and

  presented).

  register the domain name before you.

  • The text of the work is displayed

  (for example, in a slide presentation

  or on television).

  A “limited publication” is also not con-

  Dealing With the Copyright Office

  sidered a publication. A limited publication

  The Copyright Office has an enormous

  occurs if copies are distributed only:

  workload (they handle over 700,000

  • to a selected group of people

  applications per year), so it can take several

  • for a limited purpose, and

  months for your application to be processed.

  • without the right of further

  Indeed, the Copyright Office says that the

  reproduction, distribution, or sale.

  average processing time is six to ten months

  For example, it is not a publication when

  for online registrations and ten to 15 months

  an author sends copies of a manuscript to

  for paper form registrations. If you apply for

  several publishers seeking publication.

  copyright registration online, you will receive

  confirmation by email that your application

  has been received. You can also monitor the

  If you fill out the application correctly,

  progress of your application online. This is

  the Copyright Office will email you a

  not possible with applications by mail. Be

  notification of preregistration which will

  patient and remember that the registration is

  CHAPTER 3 | COPYRIGHT REGISTRATION | 89

  effective on the date it is received (assuming

  The rule of doubt

  the forms were fil ed out properly), not the

  As a matter of policy, the Copyright Office

  date you actually receive your registration

  will usually register a work even if it has a

  certificate.

  reasonable doubt as to whether the work

  The Cop
yright Office will eventually

  is copyrightable or the other requirements

  respond to your application in one of three

  have been met. This is called the rule of

  ways:

  doubt. The Copyright Office takes the

  • If your application is acceptable, the

  view that determining a copyright’s validity

  Copyright Office will send you a

  in such cases is a task for the courts. For

  registration certificate, which is merely a example, the office would ordinarily register copy of your application with the official a new edition of a previously registered

  Copyright Office seal, registration date, work under the rule of doubt, even though

  and number stamped on it. Be sure to

  it had a reasonable doubt whether the

  retain it for your records.

  edition contained enough new expression

  • If your application contained errors

  to be registrable. When registration is made

  or omissions the Copyright Office

  under the rule of doubt, the Copyright

  believes are correctable, a copyright

  Office will ordinarily send the applicant a

  examiner may phone or email you for

  letter cautioning that the claim may not be

  further information. Or he or she may valid and stating the reason.

  return the application or deposit with

  a letter explaining what corrections to

  Clearly unregistrable material

  make.

  • If the Copyright Office determines

  The Copyright Office will refuse to register

  that your work cannot be registered, it a work that is without doubt unprotectable.

  will send you a letter explaining why.

  For example, the Copyright Office would

  Neither your deposit nor fee will be

  not register a title, since titles are not copy-

  returned.

  rightable, nor would a work clearly in the

  public domain be registered (for instance, the

  King James version of the Bible) unless the

  Extent of Copyright Examiner’s

  Review of Your Application

  applicant added protectable material to it.

  The copyright examiner will examine

  Presence of errors or omissions

  your deposit to see whether it constitutes

  The Copyright Office will not issue a

  copy rightable subject matter and review

  certificate if the application contains errors

  your application to determine whether the

  or omissions or is internally inconsistent

  other legal and formal requirements for

  or ambiguous. Here are some of the more

  registration have been met.

  common errors:

  90 | THE COPYRIGHT HANDBOOK

  • failure to sign the application

  Review of Copyright Office’s

  • failure to pay the application fee

  Refusal to Register Application

  • failure to provide the required number

  of deposit copies

  If you think the copyright examiner has

  • failure to adequately describe the

  wrongfully refused to register your work,

  nature of authorship

  you may submit a written objection to the

  • deposit does not match description of

  refusal and request that the Copyright

  nature of authorship

  Office reconsider its action. The appeal

  • nature of authorship is described by a

  letter should be addressed to:

  title or identifying phrase

  U.S. Copyright Office Receipt Analysis

  • failure to provide the publication date

  and Control Division

  • the work-made-for-hire box is checked,

  P.O. Box 71380

  but the employer is not listed as the

  Washington, DC 20024-1380

  copyright claimant

  The first request for reconsideration must

  • failure to state how ownership was

  be received in the Copyright Office within

  transferred where copyright claimant is three months of the date of the office’s

  not the same as the author

  first refusal to register, and the envelope

  • failure to identify adequately the

  containing the request should be clearly

  material added to a new version or

  marked: “First Reconsideration.” A $250 fee

  derivative work (Space 6b), and

  is charged to process an appeal.

  • date application is signed is prior to

  If the claim is refused after reconsideration,

  publication date in application.

  the head of the appropriate Examining

  The Copyright Office will ordinarily

  Division section will send you written notice

  call you or send a letter asking you to fix

  of the reasons for the refusal. After this, you

  technical errors such as these. Reread our

  may again request reconsideration in writing.

  discussion about how to complete the

  This second appeal must be received in the

  application forms to help you make your

  Copyright Office within three months of the

  corrections. Send your corrected application date of the office’s refusal of the first appeal.

  or new deposit back to the Copyright Office

  A second appeal costs $500 to process and

  in one package.

  is handled by the Copy right Office Board

  Be sure you respond within 120 days to

  of Review, which consists of the Register of

  any correspondence from the Copyright

  Copyrights, the general counsel, and the

  Office concerning your application. Other-

  chief of the Examining Division. The chair

  wise, your file will be closed, your fee will

  of the Board of Review will send you a

  not be returned to you, and you’ll have to

  letter setting out the reasons for acceptance

  reapply by sending in a new application,

  or denial of your claim. The board’s

  deposit, and fee.

  CHAPTER 3 | COPYRIGHT REGISTRATION | 91

  decision constitutes the Copyright Office’s

  actual y copied from them or others. Such

  final action. You may then bring a legal

  accusations are easily disproved if the work

  action to have a court review the Copyright you claim was infringed upon was deposited

  Office’s decision. In addition, you can

  with the Copyright Office before the

  bring a copyright infringement action

  infringing work or other work the infringer

  notwithstanding the Copyright Office’s

  claims you copied was written or published.

  refusal to register your work. You’ll need

  In this event, you just need to submit to

  to see a lawyer about this. (See Chapter 15,

  the court a certified copy of the deposit you

  “Help Beyond This Book.”)

  made with the Copyright Office.

  The Copyright Office will provide

  certified copies of deposits of registered

  Full-Term Retention of

  works that are involved in litigation. But,

  Deposits and Other Ways

  of course, such copies can be made only if

  to Preserve Deposits

  the Copyright Office still has the deposit.


  Whether or not your application is accepted, So you might be in for trouble if the

  your deposit becomes the property of the

  infringement litigation takes place more

  U.S. government and will never be returned than five years after the work was registered to you. The Library of Congress may add the and the deposit has been destroyed by the

  deposit to its own col ection. If the Library

  Copyright Office.

  chooses not to do so (which is usual y the

  If you want to protect against this possi-

  case), and your application is accepted, the

  bility, you may request full-term retention

  Copyright Office will retain the deposit in

  of your deposit. Full-term retention means

  its own storage facilities for five years. Due to that the Copyright Office will retain one a lack of storage space, the Copyright Office copy of your deposit for 75 years from the normal y destroys all deposits of published

  date of publication. You must request full-

  works after five years. However, the Copy-

  term retention in writing and pay a $540

  right Office may not destroy a deposit of an

  fee. Only the person who made the deposit,

  unpublished work without first making a

  the copyright owner, or an authorized

  copy of it.

  representative may make the request. You

  can make this request when you register

  the work or any time thereafter. There is no

  Ful -Term Retention of Deposits

  form for this purpose. Send a letter to the

  People sued for copyright infringement have Chief, Information and Reference Division,

  been known to attempt to turn the tables

  Copyright Office, Library of Congress,

  on their accusers and claim that the accusers Washington, DC 20559, stating that you

  92 | THE COPYRIGHT HANDBOOK

  desire full-term retention of your deposit.

  must not unseal or otherwise tamper with

  Identify the deposit by title, author, and

  the envelope. However, this method is not

  registration number. If you request full-term foolproof, because a judge or jury might not retention of your deposit when you make

  believe that you did not tamper with the

  your initial registration, you must send the

  envelope (this actual y happened in one case).

  Copyright Office an additional copy of the

  Note that emailing a digital copy to

  deposit—that is, three copies of published

  yourself instead of postal mailing a hard

  works and two copies of unpublished works. copy is not a good option. The reason?

  Email is not delivered by an independent

  government agency (the U.S. Post Office)

 

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