cussed earlier, procedures permitting the copyright
registration of restored works are not formalities in violation of the
Berne Convention. Registration is entirely voluntary for Berne works
since copyright registration of restored works is not a prerequisite
for the filing of a copyright infringement action. Registration of a
claim in a work involves significant additional work and by law
requires a fee. The Office has, however, attempted to keep the
processing work and the fees to a minimum.

2. New URAA Related Registration Procedures

Mr. Pierce observed that registration, especially of motion
pictures, is often very burdensome for foreign works, because of the
difficulty in determining original publication dates and in submitting
a copy of the work as first released. He concluded that applications
will be filed for only a small percentage of the works unless the
Office considers adopting more liberal deposit requirements such as
accepting PAL, SECAM, VHS formats or written descriptions, allowing the
registration of related works with multiple publication dates on one
application, accepting approximate publication dates, and accepting a
previously submitted deposit instead of requiring a new deposit.
Comment 6, at 2. Ms. Theg asked that deposit requirements be waived
entirely. Comment 9, at 2.

On the other side, the AAP questioned the necessity for changes in
the existing registration and recordation systems. If such changes are
made, the AAP asserted that they should not create precedent for other
registration and deposit practices. The AAP also questioned the need
for procedures allowing blanket exemptions in some instances for
depositing materials, accepting descriptive materials instead of a copy
of the work, and allowing certain collections such as photos or TV
series to be given a single identifying group name or title. The AAP is
concerned that these procedures will make it difficult for reliance
parties to identify restored works and comply with the law. The AAP
asked that the Office instead deal with special situations on a case-
by-case basis. Comment 7, at 12-16.

The procedures developed for the registration of copyright claims
for restored works must both balance the needs of applicants for
copyright registration, reliance parties, the public, and the Copyright
Office and also establish a system that will be feasible
administratively and elicit necessary information. As indicated in ou