The Shadow of the Billion-Dollar Copyright Award; National Law Review, 4/28/14

John K. Burke and Vedder Price, National Law Review; The Shadow of the Billion-Dollar Copyright Award:

"On March 18, the Ninth Circuit issued a decision with significant impact for copyright owners in Alaska Stock v. Houghton Mifflin Harcourt Pub. Co., holding that a registration for a compilation covers any copyrightable component works that are also owned by the applicant, even if the registration application did not list the title and author of each component work.

This ruling affirms that a copyright owner can obtain a single copyright registration covering a large number of works. For example, a magazine might contain over 100 separately copyrighted images along with 10 individually copyrighted articles. If the copyrights for the compilation, the photographs and the articles are held by a single owner, all of these works may be covered using a single registration by applying for a copyright in the compilation of the magazine. Using this approach, the owner is saved from needing to submit 111 separate copyright applications, each requiring a separate application and fee.

Going forward, content distributors such as website operators that regularly publish large numbers of copyrighted works must take care to ensure they only use works with the permission of the copyright owner."