UNICOLORS, INC., a California Corporation, Plaintiff-Appellee, v. H&MHENNES &MAURITZ, L.P., a New York limited partnership, Defendant-Appellant., 959 F.3d 1194

Summary

ISSUE: Whether plaintiff had a valid copyright registration for its 2011 design. HOLDINGS: [1]-District court's reasons for denying defendant's JMOL were flawed. There was no intent-to-defraud requirement for registration invalidation; [2]-It further erred in concluding that plaintiff's application for registration did not contain inaccuracies; [3]-Plain meaning of "single unit" in 37 C.F.R. § 202.3(b)(4)(i)(A) requires that the registrant first published the collection of works in a singular, bundled collection; [4]-It was an inaccuracy to register a collection of works as a single-unit publication when the works were not initially published as a singular, bundled collection; [5]-District court was required to request the Register of Copyrights to advise it whether the inaccurate information, if known, would have caused the Register to refuse registration, 17 U.S.C.S. § 411(b)(2).