As an update to the Nov. 1 blog entry, we have good news! According to Robert J. Kasunic, the Associate Register of Copyrights and Director of Registration Policy & Practice, the concern for photographers about the proposal to limit the number of unpublished works per application is unwarranted. He states:
[U]nder the Group Registration of Photographs Notice of Proposed Rulemaking (“NPRM”), group registration of photographs would be limited to 750 photographs rather than the five works proposed under the new Group Registration of Unpublished Works. We are still working on the Group Registration of Photographs final rule in conjunction with the public comments received in that rulemaking. In any case, we fully intend to finalize that rule before finalizing the Group Registration of Unpublished Works final rule for which we are still accepting comments until November 13, 2017. So the bottom line is that we have never intended to limit a group of unpublished photographs to five photographs, but rather the number we proposed for a group of unpublished photographs was 750. The Group Unpublished Works would not be applicable to photographers unless, for some reason, a photographer wanted to register two to five photographs.
Jeff Sedlik also reports that a new form, “GRUPH” (Group Registration of Unpublished Photographs), will be made available in the near future to provide for registrations specific to photographers.
In the meantime, photographers should follow current eCO instructions for group registrations. Whew!Check Photo Attorney on Lynda.com, in the Lynda.com Article Center, and on Twitter!