throbber
No. 17-571
`
`
`IN THE
`Supreme Court of the United States
`__________
`
`
`
`
`
`FOURTH ESTATE PUBLIC BENEFIT CORPORATION,
`Petitioner,
`
`
`v.
`
`
`WALL-STREET.COM, LLC AND JERROLD D. BURDEN,
`Respondents.
`
`__________
`
`On Petition for a Writ of Certiorari
`to the United States Court of Appeals
`for the Eleventh Circuit
`__________
`
`REPLY BRIEF FOR PETITIONER
`__________
`
`
`JOEL B. ROTHMAN
`JEROLD I. SCHNEIDER
`SCHNEIDER ROTHMAN
` INTELLECTUAL PROPERTY
` LAW GROUP, PLLC
`4651 N. Federal Highway
`Boca Raton, Florida 33431
`(561) 404-4350
`
`
`December 13, 2017
`
`AARON M. PANNER
` Counsel of Record
`GREGORY G. RAPAWY
`COLLIN R. WHITE
`KELLOGG, HANSEN, TODD,
` FIGEL & FREDERICK, P.L.L.C.
`1615 M Street, N.W.
`Suite 400
`Washington, D.C. 20036
`(202) 326-7900
`(apanner@kellogghansen.com)
`
`
`
`

`

`RULE 29.6 STATEMENT
`Pursuant to this Court’s Rule 29.6, petitioner
`Fourth Estate Public Benefit Corporation states that
`it is a public benefit corporation that has not issued
`any stock.
`
`

`

`
`
`ii
`
`TABLE OF CONTENTS
`
`Page
`RULE 29.6 STATEMENT ........................................... i
`TABLE OF AUTHORITIES ...................................... iii
`ARGUMENT ............................................................... 2
`I. THE QUESTION PRESENTED MER-
`ITS REVIEW ................................................... 2
`II. THE ELEVENTH CIRCUIT’S JUDG-
`MENT IS INCORRECT .................................. 5
`CONCLUSION .......................................................... 11
`
`
`
`
`
`
`
`
`

`

`
`
`iii
`
`TABLE OF AUTHORITIES
`
`Page
`
`CASES
`Apple Barrel Prods., Inc. v. Beard, 730 F.2d 384
`(5th Cir. 1984) ...................................................... 11
`Bruesewitz v. Wyeth LLC, 562 U.S. 223 (2011) ....... 11
`Cosmetic Ideas, Inc. v. IAC/Interactivecorp,
`606 F.3d 612 (9th Cir. 2010) ................................. 3
`Lakedreams v. Taylor, 932 F.2d 1103 (5th Cir.
`1991) ..................................................................... 11
`Petrella v. Metro-Goldwyn-Mayer, Inc., 134 S.
`Ct. 1962 (2014)....................................................... 4
`
`
`
`STATUTES AND RULES
`Copyright Act of 1976, Pub. L. No. 94-553,
`90 Stat. 2541 .................................................... 9, 10
`Copyright Act (17 U.S.C.) ........................ 1, 3, 4, 5, 8, 9
`
`17 U.S.C. § 102(a) .................................................. 8
`
`17 U.S.C. § 106 ...................................................... 8
`
`17 U.S.C. § 408 ...................................................... 8
`
`17 U.S.C. § 408(c)(3) .............................................. 6
`
`17 U.S.C. § 408(f) .................................................. 4
`
`17 U.S.C. § 408(f)(1) .............................................. 8
`
`17 U.S.C. § 408(f)(3) .............................................. 8
`
`17 U.S.C. § 408(f)(3)(A)-(C) ................................... 8
`
`17 U.S.C. § 410(a) .................................................. 5
`
`17 U.S.C. § 410(d) .............................................. 7, 8
`
`

`

`
`
`iv
`17 U.S.C. § 411(a) ..................... 1, 2, 3, 5, 6, 7, 9, 11
`
`17 U.S.C. § 411(b) .................................................. 7
`
`17 U.S.C. § 411(c) ....................................... 4, 5, 6, 8
`
`17 U.S.C. § 411(c)(2) .............................................. 6
`
`17 U.S.C. § 412 ...................................................... 6
`
`17 U.S.C. § 505 ...................................................... 4
`
`Sup. Ct. R. 10(a) .......................................................... 1
`
`
`LEGISLATIVE MATERIALS
`Copyright Law Revision: Report of the Register
`of Copyrights on the General Revision of the
`U.S. Copyright Law, 87th Cong. (Comm.
`Print 1961), available at https://www.
`copyright.gov/history/1961_registers_report.
`pdf ........................................................................ 10
`Copyright Law Revision: Studies Prepared for
`the Subcomm. on Patents, Trademarks, and
`Copyrights of the S. Comm. on the Judici-
`ary, 86th Cong. (Comm. Print 1960), avail-
`able at https://www.copyright.gov/history/
`studies/:
` Study No. 17 – The Registration of Copy-
`right ...................................................................... 10
` Study No. 18 – Authority of the Register of
`Copyrights To Reject Applications for Regis-
`tration .................................................................. 10
`H.R. Rep. No. 94-1476 (1976), reprinted in
`1976 U.S.C.C.A.N. 5659 ............................... 8, 9, 10
`H.R. Rep. No. 103-388 (1993) ................................... 11
`
`

`

`
`
`v
`
`OTHER MATERIALS
`2 Melville B. Nimmer & David Nimmer,
`Nimmer on Copyright (2013)..........................3, 5, 9
`
`
`
`
`
`

`

`Respondents concede that the Eleventh Circuit
`“has entered a decision in conflict with the decision of
`another United States court of appeals,” Sup. Ct. R.
`10(a), with respect to the meaning of the phrase
`“registration . . . has been made” in § 411(a) of the
`Copyright Act, 17 U.S.C. § 411(a). They do not
`contend that this conflict will be resolved absent this
`Court’s review, nor do they deny that the question is
`cleanly presented in this case. Instead, they devote
`most of their brief to defending the Eleventh Circuit’s
`rule. But arguments that the decision below is cor-
`rect do not lessen the need for review. If respondents
`are right, the rule in two regional circuits – including
`the largest – permits copyright infringement actions
`to proceed in violation of the statute. That is reason
`enough to grant the petition.
`Respondents argue that the importance of the
`question presented is modest, and, viewing the
`importance of the case through the lens of any
`particular infringement action, that will often (though
`not always) be true. But this procedural issue is pre-
`sented at the threshold of virtually every copyright
`infringement action. Uncertainty over this question
`– which eight regional circuits have yet to resolve –
`invites needless litigation. Once this Court resolves
`the question, litigants will be able to abide by the
`rule, but, as long as the question remains unresolved,
`there is the prospect of needless delay and litigation
`– and, at least in the Tenth and Eleventh Circuits,
`the needless expenditure of funds to avoid protracted
`administrative delay.
`Respondents’ merits position echoes the key flaw of
`the decision below: it reads the word “registration”
`in isolation from its context. Consistent with common
`usage, Congress used the word “registration” in the
`Copyright Act in different ways. Sometimes it refers
`
`

`

`
`
`2
`to the action of the Copyright Office. Other times –
`particularly when used in the construction “make
`registration” – it refers to the actions of the copyright
`holder. Its use in § 411(a) falls in the latter category.
`And for good reason: barring a copyright owner from
`enforcing a copyright until after the Copyright Office
`disposes of the application pointlessly delays an
`action that will proceed regardless of whether the
`Copyright Office grants or refuses registration. The
`requirement of § 411(a) – as the plain language of the
`statute makes clear – is to ensure that copyright
`holders make registration before filing suit, not to
`ensure that the Copyright Office grants it.
`The Court should grant the petition and reverse
`the judgment of the Eleventh Circuit.
`ARGUMENT
`I. THE QUESTION PRESENTED MERITS
`REVIEW
`Respondents concede that the question presented
`has split the lower courts. Opp. 2; see also Pet. 9-15.
`The Court should resolve that conflict and do so in
`this case.
`Respondents do not contend that permitting addi-
`tional courts of appeals to weigh in on the question
`presented would yield either new arguments or
`resolution without this Court’s review. It would not.
`The issue is narrow, yet the split has only deepened
`over time. Nor do respondents identify any reason
`this Court cannot resolve this confusion in this case.
`None exists.1
`
`1 After the petition was filed, counsel for the Copyright Office
`provided counsel for petitioner with an unsigned draft of a
`letter (dated August 4, 2017) rejecting petitioner’s application
`for registration. Assuming that petitioner’s application has now
`
`

`

`
`
`3
`Respondents’ position that the split is not impor-
`tant enough to warrant resolution is undermined by
`their extended focus on the merits. See Opp. 9-21.
`On their telling, the courts that have adopted
`petitioner’s rule are in conflict with the Copyright
`Act’s plain text, disregarding copyright defendants’
`rights and undermining the Copyright Office’s role
`as gatekeeper to the courts. Respondents misread
`the statute, but, if they were right, those would be
`reasons to grant review, not to deny it.
`Further, like the court below, see App. 8a, respon-
`dents admit their rule’s consequence if the Copyright
`Office fails to process an application promptly: the
`copyright owner can lose damages or, in the worst
`case, an entire claim. Opp. 6-7; see also 2 Melville
`B. Nimmer & David Nimmer, Nimmer on Copyright
`§ 7.16[B][3][b][iii] (2013) (respondents’ rule “may indeed
`occasion complete inability to recover damages”)
`(footnote omitted). They never dispute that their
`rule can preclude preliminary injunctive relief –
`a vital remedy for many copyright owners. See
`Cosmetic Ideas, Inc. v. IAC/Interactivecorp, 606 F.3d
`612, 620 (9th Cir. 2010); 2 Nimmer on Copyright
`§ 7.16 n.214 (“in some cases, a preliminary injunction
`is of the essence,” and the rule respondents endorse
`“could effectively squelch that remedy, too”). Nor
`do respondents deny that, even where the owner
`does not lose a remedy, their rule may require the
`copyright holder to re-file the same infringement
`action after the Copyright Office has acted, burdening
`both parties and courts with duplicative litigation.
`
`been acted on, that does not moot the controversy in this case,
`which depends on whether the allegations of the complaint –
`that petitioner had made the deposit, application, and fee required
`for registration – satisfy § 411(a).
`
`

`

`
`
`4
`The question presented does not become un-
`important because a copyright owner can expedite
`an application by paying the Copyright Office an
`$800 “special handling” fee. Opp. 7-8. At the outset,
`when a copyright holder seeks relief for infringement
`of multiple works, all requiring separate registration,
`the cost of expediting the administrative process may
`easily amount to many thousands of dollars. To be
`sure, the special handling fee will usually be smaller
`than the expected costs of copyright litigation (though
`not always: a prevailing copyright owner may recover
`attorney’s fees, 17 U.S.C. § 505). But the observation
`that litigation is expensive is not a reason to ignore a
`rule that makes it more expensive still.
`No other source of law respondents identify fully
`mitigates these harms. True, the Copyright Act
`qualifies the registration requirement in certain
`cases. See 17 U.S.C. § 411(c) (live broadcasts); id.
`§ 408(f) (preregistration for certain works prepared
`for commercial distribution). But those provisions
`do nothing to help the many copyright owners that,
`like petitioner, do not fall within their protections.
`Similarly, respondents observe that, “in a case
`involving ongoing (rather than separate) violations
`that began more than three years previously,” the
`rule they endorse would not deprive a copyright
`owner of a claim, but merely move the damages
`period. Opp. 7 (citing Petrella v. Metro-Goldwyn-
`Mayer, Inc., 134 S. Ct. 1962, 1969 n.6 (2014)). But,
`as respondents concede (id.), reducing a copyright
`holder’s recovery is “a legitimate concern” in its
`own right, and one for which respondents have no
`answer.2
`
`2 Respondents (at 2, 6) selectively quote part of Professor
`Nimmer’s aside that, “[i]n some sense,” this conflict is a
`
`

`

`
`
`5
`In all events, assuming that a copyright holder
`may usually be able to avoid the worst consequences
`of delay by the Copyright Office, the uncertainty
`engendered by the current division of authority
`affects countless cases in which this issue is impli-
`cated. The rule adopted by the court of appeals
`would require many copyright holders either to delay
`suit or to incur hundreds if not thousands of dollars
`in fees to expedite the administrative process. In
`the majority of circuits where the rule is unsettled,
`parties may needlessly litigate over the issue, as they
`have done in this case. The systemic cost is substan-
`tial, and the issue is important for that reason.
`II. THE ELEVENTH CIRCUIT’S JUDGMENT IS
`INCORRECT
`1. Respondents insist that the term “registra-
`tion,” whenever it is used in the Copyright Act, must
`refer to the action of the Register of Copyrights
`under § 410(a) – that is, issuing a certificate of
`registration. Accordingly, they argue, the phrase
`“registration . . . has been made” in § 411(a) must
`mean that the Copyright Office has registered the
`work. But the argument that “registration” always
`implies action by the Register cannot be squared
`with the statutory text.
`Section 411(c) – with which respondents grapple
`unsuccessfully for three pages of their brief – most
`
`
`“tempest in a teapot” because “plaintiffs could always avoid dis-
`missal of their case by filing a new application for registration
`with the Copyright Office on an expedited basis.” 2 Nimmer on
`Copyright § 7.16[B][3][b][v]. In the same paragraph, however,
`he goes on to catalog the problems with that solution: it
`requires “payment of a stiff charge” and the potential “loss of
`vital remedies,” which might “render[] [the copyright owner’s]
`suit pointless.” Id.
`
`

`

`
`
`6
`clearly demonstrates respondents’ error.3 That pro-
`vision allows a copyright owner to institute an action
`for infringement of certain types of works so long
`as “the copyright owner . . . makes registration for
`the work[s]” within three months of instituting suit.
`17 U.S.C. § 411(c)(2) (emphasis added). That provi-
`sion thus makes explicit who “makes registration”:
`the “copyright owner.” It is thus natural to read the
`parallel construction in § 411(a) – “registration . . . has
`been made” – likewise to refer to the action of the
`copyright owner.
`Respondents assert that § 411(c) actually “require[s]
`the Register” – not the copyright owner – “to have
`acted” within three months. Opp. 13 (emphasis
`added). But the language of the provision is to the
`contrary. It permits a copyright owner to seek injunc-
`tive relief so long as the copyright owner takes action –
`that is, makes registration – within the prescribed
`time. The provision does not require the copyright
`owner to have obtained a certificate of registration,
`nor does it refer to any action of the Copyright Office.
`Section 411(c)’s requirement to make registration is a
`
`
`3 Respondents do not even address the other provisions of
`the statute that similarly use “make registration” or a variant
`to refer to the actions of the copyright holder. See 17 U.S.C.
`§ 408(c)(3) (“a single renewal registration may be made for a
`group of works by the same individual author . . . upon the
`filing of a single application and fee”); id. § 412 (“[N]o award of
`statutory damages or of attorney’s fees . . . shall be made for . . .
`any infringement of copyright commenced after first publication
`of the work and before the effective date of its registration,
`unless such registration is made within three months after the
`first publication of the work.”); Pet. 20-21.
`
`

`

`
`
`7
`procedural obligation placed on the copyright owner;
`the same is true of § 411(a).4
`Section 411(b) does not support a different result.
`It clarifies that (with narrow exceptions) a copyright
`owner may rely on a certificate of registration even if
`it contains inaccurate information. But the fact that
`an inaccurate certificate is not disqualifying does
`not suggest that every infringement plaintiff will be
`able to provide a certificate of registration – on the
`contrary, all agree that in some cases (for example,
`when registration has been refused) the copyright
`owner will not have such a certificate. Likewise,
`in those cases where a copyright owner has made
`registration but has not yet received a certificate,
`§ 411(b) will not apply – but that does not render it
`superfluous.
`Contrary to respondents’ argument (at 10), petition-
`er’s interpretation of § 411(a) is in no tension
`with § 410(d), which establishes the effective date of
`registration. As respondents acknowledge, petitioner
`does not contend that registration cannot refer to the
`action of the Copyright Office. By the same token,
`there is no linguistic reason that the “effective date of
`a copyright registration” – which affects the rights
`and remedies of infringers – could not be the date on
`which a certificate of registration is issued. But the
`statute makes clear that the effective date is instead
`the date on which the “application, deposit, and fee”
`
`4 Respondents have no answer to the argument that their
`reading creates a contradiction between the first and second
`sentences of § 411(a). See Pet. 18-19. Nor does § 411(a)’s
`second sentence suggest that a copyright owner must obtain a
`certificate of registration to sue under § 411(a)’s first sentence –
`rather, it clarifies that, if a copyright owner whose application
`is rejected initiates suit, the copyright owner must notify the
`Copyright Office.
`
`

`

`
`
`8
`are received, 17 U.S.C. § 410(d) – that is, the date
`on which the copyright owner makes registration, not
`the date on which the Copyright Office registers the
`claim.
`Section 408(f)(3) – which speaks to works that a
`copyright owner, anticipating commercial distribution,
`preregisters while they were unpublished, see id.
`§ 408(f)(1) – does not, as respondents suggest (at 15),
`show that Congress distinguished “making registra-
`tion” from “applying for” registration. Indeed, the
`latter phrase does not appear in § 408. The statute
`provides that, “[n]ot later than 3 months after
`the first publication of a work preregistered under
`this subsection, the applicant shall submit to the
`Copyright Office” the same three things she would
`have to submit to register any other claim: “an
`application for registration of the work,” “a deposit,”
`and “the applicable fee.” 17 U.S.C. § 408(f)(3)(A-C).
`By taking these actions, the copyright owner makes
`registration of the work – as § 411(c) and other
`provisions make clear.
`2. Respondents do not seriously dispute that
`petitioner’s reading is more consistent, as well, with
`the Copyright Act’s remedial scheme. Again (and
`unlike the patent laws), the Act grants copyright
`owners exclusive rights in their works from the
`moment of fixation. See 17 U.S.C. §§ 102(a), 106;
`H.R. Rep. No. 94-1476, at 129 (1976), reprinted in
`1976 U.S.C.C.A.N. 5659, 5745. And, regardless of
`whether the Register of Copyrights accepts or refuses
`registration, the copyright owner still has the right
`to sue and enforce those rights. To be sure, the
`registration requirement encourages registration,
`with related public benefits (for example, adding the
`work to the collection of the Library of Congress).
`
`

`

`
`
`9
`See Opp. 16; accord Pet. 23. “But” – again – “once
`the copyright owner has made registration, that
`policy is fully vindicated.” Pet. 23. Respondents
`never explain why the “legal limbo” their approach
`creates is necessary to further that policy. Opp. 18
`n.9.
`Nor is respondents’ rule required to secure the
`Copyright Office’s expertise in the unusual case that
`calls for it. Cf. Opp. 17. Instead, in an appropriate
`case, the court can invite the Office to act on an
`application before litigation proceeds. See Pet. 25-26.
`That is the point of Professor Nimmer’s “harmonized
`solution,” which respondents misunderstand (at 18
`n.9) to conflict with petitioner’s reading. Under
`his approach, cases filed after the owner submits
`a completed application but before the Office acts
`on that application should generally proceed on the
`merits. But, in the rare dispute that turns on
`copyrightability, the court should stay proceedings
`pending the Office’s action. See 2 Nimmer on
`Copyright § 7.16[B][3][b][vi]. As to the question
`presented, Professor Nimmer rejects respondents’
`rule and endorses petitioner’s, and for the same
`reasons: respondents’ rule conflicts with the Copy-
`right Act’s text, structure, and purpose. See id.
`§ 7.16[B][3][b][ii].
`3. Section 411(a)’s legislative history likewise
`offers respondents little support. On the contrary,
`the 1976 Act’s legislative history confirms that the
`term “registration” can, in context, refer to the copy-
`right owner’s actions – not the Copyright Office’s.
`See H.R. Rep. No. 94-1476, at 157, 1976 U.S.C.C.A.N.
`5773 (“[A] copyright owner who has not registered
`his claim can have a valid cause of action against
`someone who has infringed his copyright, but he
`
`

`

`
`
`10
`cannot enforce his rights in the courts until he has
`made registration.”) (emphasis added); id. at 152,
`1976 U.S.C.C.A.N. 5768 (“Under section 408(a),
`registration of a claim to copyright in any work,
`whether published or unpublished, can be made
`voluntarily by ‘the owner of copyright or of any
`exclusive right in the work’ at any time during
`the copyright term.”) (emphasis added); accord Opp.
`19 (“‘[A] copyright owner who has not registered
`his claim cannot enforce his rights in the courts.’”)
`(quoting H.R. Rep. No. 94-1476, at 157, 1976
`U.S.C.C.A.N. 5773) (alteration omitted).
`Respondents cite discussions from early in the
`unusually lengthy history of the 1976 Act, but
`statements in committee materials from 1958,5
`1959,6 and 19617 are hardly dispositive of the
`meaning of the words Congress adopted more than
`a decade later. For similar reasons, the post-1976
`Act legislative history on which respondents rely is
`also inapt. To start, “[p]ost-enactment legislative
`history (a contradiction in terms) is not a legitimate
`
`5 See Copyright Law Revision: Studies Prepared for the Sub-
`comm. on Patents, Trademarks, and Copyrights of the S. Comm.
`on the Judiciary; Study No. 17 – The Registration of Copyright,
`86th Cong. 65 (Comm. Print 1960), available at https://www.
`copyright.gov/history/studies/.
`6 See Copyright Law Revision: Studies Prepared for the Sub-
`comm. on Patents, Trademarks, and Copyrights of the S. Comm.
`on the Judiciary; Study No. 18 – Authority of the Register of
`Copyrights To Reject Applications for Registration, 86th Cong.
`89 (Comm. Print 1960), available at https://www.copyright.gov/
`history/studies/.
`7 See Copyright Law Revision: Report of the Register of
`Copyrights on the General Revision of the U.S. Copyright Law,
`87th Cong. 75 (Comm. Print 1961), available at https://www.
`copyright.gov/history/1961_registers_report.pdf.
`
`

`

`
`
`11
`tool of statutory interpretation.” Bruesewitz v. Wyeth
`LLC, 562 U.S. 223, 242 (2011). Moreover, although
`statements in those materials appear to assume
`respondents’ view of § 411(a),8 they ignore contrary
`circuit-level authority. See Lakedreams v. Taylor,
`932 F.2d 1103, 1108 (5th Cir. 1991); Apple Barrel
`Prods., Inc. v. Beard, 730 F.2d 384, 386-87 (5th
`Cir. 1984) (citing then-current version of Nimmer on
`Copyright). A post-enactment gloss in a committee
`report provides no basis to ignore the text of the
`statute.
`
`CONCLUSION
`The petition for a writ of certiorari should be
`granted.
`
`
`8 See, e.g., H.R. Rep. No. 103-388, at 9-11 (1993) (speaking
`of a “requirement that a registration or refusal to register be
`obtained from the Copyright Office before an action for infringe-
`ment be obtained”).
`
`

`

`
`
`
`
`JOEL B. ROTHMAN
`JEROLD I. SCHNEIDER
`SCHNEIDER ROTHMAN
` INTELLECTUAL PROPERTY
` LAW GROUP, PLLC
`4651 N. Federal Highway
`Boca Raton, Florida 33431
`(561) 404-4350
`
`
`December 13, 2017
`
`
`
`
`12
`Respectfully submitted,
`
`AARON M. PANNER
` Counsel of Record
`GREGORY G. RAPAWY
`COLLIN R. WHITE
`KELLOGG, HANSEN, TODD,
` FIGEL & FREDERICK, P.L.L.C.
`1615 M Street, N.W.
`Suite 400
`Washington, D.C. 20036
`(202) 326-7900
`(apanner@kellogghansen.com)
`
`

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