Alaska Stock v. Houghton Mifflin, No. 10-36010 (9th Cir. 2014)
Annotate this CaseAlaska Stock, a stock photography agency, registered large numbers of photographs at a time under the Copyright Act, 17 U.S.C. 101 et seq., listing only some of the authors and not listing titles for each photograph. Alaska Stock licensed Houghton Mifflin to use pictures it had registered, for fees based on the number of publications. After Houghton Mifflin greatly exceeded the number of publications it had paid for, Alaska Stock filed suit for injunctive relief, actual and statutory damages, attorneys' fees, and costs. The court concluded that Alaska Stock successfully registered the copyright both to its collections and to the individual images contained therein; the statute required identification of the author and title of the "work," which was the collective work, and extended registration to the component parts if the party registering the collective work owned the copyright to the component parts, as Alaska Stock did; the procedure applied for over three decades by the Register of Copyrights to registration by stock photo agencies complied with the statutory requirements and did not violate any clear requirement to list individual authors and titles of the components within the work; the Register of Copyrights' reading that a collection of stock photos may be registered without individual titles, and without naming more than three of the authors and merely designating the number of authors, pursuant to an assignment in the language Alaska Stock used, was reasonable and persuasive; and therefore, the court reversed the district court's dismissal.
Court Description: Copyright. Reversing the district court’s dismissal of a copyright infringement action, the panel held that copyright registration of a collective work registers the component works within it. The panel held that the Register of Copyrights had authority to prescribe a form and grant certificates extending registration to individual stock photographs within a collection where the names of each of the photographers, and titles for each of the photographs, were not provided on the registration applications. Agreeing with other Circuits, and deferring to the Copyright Office’s interpretation of the Copyright Act, the panel held that where the photographers had assigned their ownership of their copyrights in their images to the stock agency, and the stock agency had registered the collection, both the collection as a whole and the individual images were registered.
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