We are “blue in the face” in large measure because we keep cajoling, pleading, begging and even yelling (we are both New Yorkers ya’ know) that everyone ought register their copyrights with the US Copyright Office all of the time, always, no exceptions. As with all rules, along comes the apparent real life exception to our rule. It arises from legal advice that was given to a photographer from a photographer who wants to be a lawyer. The trouble with getting information from Internet experts, rather than lawyers, is they may posses what we call a “factoid”. Something that has a grain of truth so it sounds right, but is off the mark enough to not only be wrong, but off enough to cause you great distress (and loss of money).
Here is the slightly altered, but still real life scenario:
Photographer resides in, let’s say for example, the UK. She creates a photo that is licensed for use on a product, for a service, or even in a magazine as an editorial. Doesn’t matter which one. The important part is that she is paid in full and published in the UK/EU in strict accordance with the license she issued to her client. Shot is not registered in the USA because her “photographer/wannabe legal expert” tells her that there is no need to register in the US because it’s published in the UK/EU. She believes him because he authors a blog in which he discusses copyright!
A year later the image appears in the USA via a willful infringement by a US company which alters the embedded metadata and removes her watermark to boot. The use is for something not remotely contemplated by the photographer nor did she ever know of or hear of the infringer.
She naturally calls her “expert” who says, “No worries. You can still sue in the US even though you haven’t registered it there”. Well the “expert’s” factoid is not entirely wrong, but rather just off the mark enough to cost the photographer lots of American greenbacks.
Here’s the legalease which we recite here not to bore you but to demonstrate how following the advice of something with a little knowledge can be a dangerous to your wallet. The Copyright Law is called Title 17 of the U.S. Code (or USC Title 17) and at Section 411(a) it states:
“Except for an action brought for a violation of the rights of the author under section 106A(a), and subject to the provisions of subsection (b),[1] no civil action for infringement of the copyright in any United States work shall be instituted until preregistration or registration of the copyright claim has been made in accordance with this title”.
Plain English translation:
For over a hundred years, the United States resisted joining the Berne Union, in part because of the desire to maintain the formalities U.S. law required – one must register to sue. In order to be eligible to join the Berne Union, Congress had to amend the Copyright Act to dispose of the many formalities the Act required.
Therefore, while the United States Copyright Act can impose a requirement that the owner of a United States work must register the copyright with the Copyright Office before filing an infringement suit in federal court, BUT it cannot impose that same obligation on foreign nationals.
The Berne convention does not require registration to file a suit (outside the USA) especially if the photo was previously and properly published in say, the EU. The U.S. finally joined the Berne Convention more than a century after it was drafted. The U.S. Congress, however, explicitly made the Berne Convention “non-executing” (hang on, exiting the “legal weeds” soon) which means that the Berne Convention has no legal effect in the courts of the U.S.; only the laws passed by Congress to conform U.S. law to the Berne Convention carry any weight.
Bottom Line: The U.S. Congress passed a law that eliminated the previous requirement that a foreign copyright holder had to register its work with the Copyright Office before being able to file a lawsuit in the USA. Thus, under the “Berne Implementation Act” a foreign rights holder (unlike a US citizen) does not need a formal registration to file a lawsuit in the U.S.. Sounds like an advantage if you are not a citizen. But the devil is in the details. But (and it’s a big but) to obtain all the benefits of U.S. copyright laws, formal registration is still required.
Or as we say here on this side of the pond, “Yikes”.
So while the UK photographer can file her case for copyright infringement in the Federal Courts in the US of A, she can not seek statutory damages, attorneys fees nor is she the presumptive owner/creator of the image. All of those remedies (especially the claims for statutory damages and attorneys fees) are now not available to her thanks to the advice of her online “expert”. She can recover actual damages only if she files and wins her case in Federal Court.
While technically correct in that she could file her case in the USA without a registration, the potential monetary value of the case in our experience was reduced by only about $125,000 give or take a few bucks. On the bright side, her expert’s advice did spare her the then $35 registration fee that she would have paid to register her entire assignment shoot of about 100 images. (She is now busy registering those works, some of which have been published, some not, necessitating multiple applications and at the increased filing fee of $55 now in effect).
And what of her “photographer/wannabe legal expert”, the source of copyright infringement wisdom? Did he go on to law school? Did his photo career take off? Nope. It seems that he has something to do with the wholesale distribution of food products in one of the smaller EU nations and no longer blogs nor creates photos.
So once again let us raise our voices to chant in unison, “Register everything, all of the time, no exceptions”.
#1 by Kenneth Salstrom on June 6, 2017 - 11:44 am
If I’m not sure if a photo is considered to be published should I register as published or unpublished?
#2 by Jack and Ed on June 19, 2017 - 5:48 pm
Kenneth, We don’t have an answer for that. You have to make the determination if it’s published or not. Our suggestion is call the Copyright Office directly and ask someone there. They are very helpful (and nice) once you get through.
Registering a published image as unpublished could get it disqualified in court.
#3 by Ed Greenberg on June 23, 2017 - 5:42 pm
I (or any attorney) would need to know WHY you are unsure if it is or is not considered published. Knowing the circumstances surrounding any use of the image might result in a simple answer.
You can get advice from the copyright office but understand that if you follow that advice and it turns out to be wrong you are stuck. Their advice is generally reliable but your reliance on their accuracy is not guaranteed
#4 by Kenneth Salstrom on July 19, 2017 - 4:53 pm
I’m an amateur and have exhibited photos for sale but have not sold any for several years. I’m not 100% sure which one’s I have exhibited.
#5 by Derek G on August 9, 2017 - 1:14 am
Hi Ed and Jack,
I am looking to register copyrights for some photography I took under a pseudonym in order to separate my more commercial work from my more artistic/abstract work and had a few questions about the potential pitfalls:
1. After looking up the Copyright Office Instructions on pseudonym use, I’m assuming even if you list a pseudonym and check the pseudonym box you should still put your real name under the author section otherwise proving ownership at a later date may be more difficult? At least that’s what the Copyright Office documentation warns. Would you agree it is not advisable to leave the author or creator section empty and only list a pseudonym, for this reason?
2. What if I published a previous image under my real name but want to register it now under a pseudonym as I now consider it part of my commercial work which I’d like identified with a pseudonym. Is this possible? Does registering it now under a pseudonym that it was not originally published under (but never registered) change its status as a published vs unpublished work?
I know this sounds like a lot of over-complication, but I really want to try to maintain two distinct entities for different kinds of work.
Your advise on this would be greatly appreciated. Thanks, Derek
#6 by Jack and Ed on August 9, 2017 - 10:40 am
Hi Derek,
I think you’re being overly cautious. pseudonyms are for things like Cary Grant registering Cary Grant, yet his real name was Archibald Leach.
Just who is going to search to search to see that you registered with a pseudonym? Even in the very, very, very rare case, they couldn’t see your images unless they pay a small fortune to the copyright office to retrieve it. And that’s if they can find it. (That’s why we tell people to retain an exact copy of what they sent to the Copyright Office).
As a photographer who was known commercially and editorially for different styles, and promoted separately those styles, I can tell you some clients love to see there is more sides to you and your work. As you said, I think you’re making over complicated. I would just register everything in your name. I don’t think you’ll see any issues down the road. Unless there is more to this than you’re explaining.
As far as your question #2, you can’t double register a photo. You can alter a previous registration for a fee, but you can’t “re-register” your work. That, double registering, could invalidate the registration. There is a question in the registration process asking if any of the work has been previously registered. This is for works that contain other work that is registered, like a new book with photos registered previously. You then have to state what was previously registered, to separate that work out of the new registration. That is how the Copyright Office avoids a double registration with new works that incorporate previously registered work.
I think it would serve you best to work in the KISS mode. Keep it simple.
#7 by Derek G on August 11, 2017 - 4:52 pm
Jack and Ed, thanks very much for your advice above on pseudonyms. My desire to separate my commercial work from my fine art/abstract work has to do with advice from gallery owners I have worked with who heavily caution about selling one’s work at reduced prices in different venues. I want to try to mass market some of my truly commercial shots on a website I have created designed to bring in a lot of general traffic, but not necessarily fine art traffic. I am experimenting with trying to sell at higher volume but at much reduced prices. Naturally, these will be different images than the ones I sell as Fine Art elsewhere.
I’ve just had it brow-beaten into my psyche that one does not want to muddy the waters as to what kind of photographer/artist you are when trying to market yourself. (I.e., let’s say a new gallery is googling you to see what other kind of work you’ve done before getting into business with you and sees that you have this very commercial site designed to sell other images at quite reduced prices and feels this compromises your artistic credentials or worth and limits what they want to try to sell your fine art pieces for). Perhaps this is entirely wrong based on what you are saying above. And what you say, does make me want to just register it all under my legal name and just be done with such complexities.
Regarding answer to #2 above, I was really asking about registering an image under a pseudonym if that image was originally published (rather than already registered) under your real name. Is that possible?
Thanks very much, Derek
#8 by Jack and Ed on August 23, 2017 - 1:06 pm
Derek, I think where the disconnect here is that you think people will see your registered images at the Copyright Office. Try to look up someone’s images today. I wouldn’t worry about that for a second.
Yes, you can publish under one name and register under another, but why complicate it? I’d have two different identities in the real world to promote two different styles, but then I’d register everything under my real name. No one is going to look up registrations and images.