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Copyright registration obtained more than five years after publication does not constitute prima facie evidence of valid copyright ownership. Transfer of rights must be accompanied by a written conveyance or a later written confirmation of transference.

Opinion (Koh): The Art of Living Foundation (AOLF-India) is based in India, with a chapter in the United States (AOLF-US). AOLF-US brought suit against “Skywalker” and “Klim” for blogging teaching manuals written by AOLF. Skywalker and Klim were former members of AOLF, but had since been critical of the foundation. AOLF-US had a copyright registration for the manuals, but because it was obtained more than five years after the original publication, the court looked to other evidence to corroborate the certificate. A declaration by AOLF-US said the manuals were written by AOLF for AOLF-India, showing that the copyright belonged to AOLF-India rather than AOLF-US. Absent any evidence that AOLF-US made any “non-trivial, original” contributions to the manual, the court gave the copyright registration no weight as evidence. In the alternative, AOLF-US claimed that AOLF-India transferred its rights to AOLF-US, just without the necessary written conveyance or written memorandum memorializing the transference. Because AOLF-US was unable to provide any evidence of its ownership of the copyright, the court GRANTED Skywalker and Klim’s motion for summary judgment on AOLF-US’s copyright claims.