Unicolors, Inc. v. H&M Hennes & Mauritz, L.P.
Overview
Overview
The Supreme Court held 6-3 that copyright registration is valid even when the application contained inaccurate information, so long as the copyright holder did not have actual knowledge that the information was inaccurate at the time of registration, reversing the Ninth Circuit's stricter standard.
The Facts
Facts
Unicolors, a fabric design company, obtained copyright registrations for designs that included works first sold collectively and separately, in violation of registration rules requiring separate applications. H&M challenged the registrations as invalid, arguing the inaccuracies voided Unicolors' ability to sue for infringement.
The Issue
Issue
Whether a copyright registration is invalid under the Copyright Act's safe harbor provision when the copyright holder included inaccurate information in the registration application but without actual knowledge of the inaccuracy.
The Rules
Rule
The Copyright Act provides that a certificate of registration is valid despite inaccurate information if the copyright holder had no actual knowledge of the inaccuracy at the time of registration; the safe harbor protects honest mistakes but not deliberate misrepresentations.
The Application
Analysis
Unicolors' registration application grouped works that should have been registered separately, technically violating the Copyright Act's registration rules, but the Supreme Court applied the safe harbor standard focusing on actual knowledge rather than strict liability. The majority held that a copyright holder's honest mistake in the registration process does not automatically void the registration, protecting Unicolors' enforcement rights despite the technical error. This departed from the Ninth Circuit's stricter approach, which had invalidated registrations based on technical violations alone. The Court remanded for the lower court to assess whether Unicolors actually knew of the registration requirement, making subjective intent, not technical compliance, the dispositive factor.
The Conclusion
Conclusion
Court ruled 6-3 for Unicolors. Breyer wrote the majority. Registration is not voided by honest errors; the case was remanded for the Ninth Circuit to assess actual knowledge. Barrett dissented for three justices.
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