Roger Miller Music, Inc. v. Sony/ATV Publ’g, LLC

Famed singer-songwriter Roger Miller assigned original and renewal copyrights to his songs to defendant in the 1960s. Defendant filed applications to register renewal copyrights for 1964 songs with the Copyright Office in 1992 and subsequently registered these copyrights. In 2004, plaintiff, a company formed by Miller's heirs, sued for copyright infringement. The district court held that defendant owned the renewal copyrights and held an implied, non-exclusive license to exploit the 1964 songs based on plaintiff's actions and inactions in accepting royalty payments. Defendant moved to amend the judgment, arguing that it owned the renewal copyrights because it had applied to register them prior to Miller's death. The district court refused to hear arguments on the issue. On remand, the district court concluded that defendant did not own the renewal copyrights because Miller had died prior to vesting of the renewal rights and assignees were not included in the list of statutory successors. The court awarded $903,349.17 in damages. The Sixth Circuit reversed, holding that under the Copyright Act, 17 U.S.C. 304(a)(2)(B)(i), the renewal copyright vested with Roger Miller, and thus with defendant as his assignee.