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Bell v. Combined Registry Co.
United States District Court for the Northern District of Illinois
397 F. Supp. 1241 (1975)
In 1971, Robert Bell (plaintiff) filed suit against Combined Registry Company (defendant) for its publishing of a poem to which Bell claimed he owned the copyright. Bell alleged that Max Ehrman had originally written the poem and registered a copyright in 1927, which was assigned to multiple individuals until Bell ultimately purchased the rights to the poem. Combined Registry argued that Ehrman had forfeited the copyright because he had authorized publication of the poem without the copyright notice required by the Copyright Act of 1909. The evidence supporting Ehrman’s forfeiture included: (1) Ehrman’s gratuitous authorization of a psychiatrist’s distribution of the poem to hundreds of US troops, (2) the fact that Ehrman’s conversations with the psychiatrist were informal with no mention of any copyright notice, and (3) lack of copyright notice in the copy of the poem retained by the psychiatrist.
Rule of Law
Holding and Reasoning (Flaum, J.)
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