Including Titles in Unpublished Works
Full Question: Many photographers “group-register” their unpublished images in a Standard eCO Application. Around 2011, the Copyright Office began mailing letters to these photographers, encouraging them to include a short description title (Content Title) for each photograph being registered to make their registration “bulletproof”. I’ve been using this technique since then. Does the Copyright Office continue to recommend authors of photographs and other creative media to include Content Titles for their unpublished works?
Answer: The Copyright Office recently created a new group registration option for unpublished photographs. To register a group of unpublished photographs, the applicant must complete and submit the online application designated for a group of unpublished photographs. (The Office will no longer register a group of unpublished photographs as an unpublished collection.). Another requirement that must be met is that the applicant must submit a sequentially numbered list containing a title and file name for each photograph in the group so that the Office can match the corresponding file names for each photograph submitted with the application. This list must be uploaded together with the deposit for each of the photographs. Applicants may also include titles of the individual photographs in the application itself by copying and pasting them from the required list, although this is optional. For more detailed information on using the group registration option for unpublished photographs, see 37 C.F.R. ¤ 202.4(i), Circular 42 (https://www.copyright.gov/circs/circ42.pdf), and the help text that accompanies the online application (https://www.copyright.gov/eco/help/group/gruph.html; https://www.copyright.gov/eco/help/group/grpph.html).
Rob Kasunic, Director of Registration Policy and Practices at the U.S. Copyright Office.