Bryant v. Media Rights: The Second Circuit Provides Some Further Answers About the "One-Work Limitation" on Grants of Statutory Damages Involving an Infringing Compilation

The Second Circuit in Bryant v. Media Right Production, Inc. on April 27 , 2010, further clarified the one-work limitation in copyright litigation set forth in the last sentence of 17 U.S.C. § 504 (c)(1). This limitation has bedeviled courts and parties because of its ambiguity. It provides that, for purposes of determining the number of grants…

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