204 and copyright license

Radio Television Espanola S.A. v. New World Entertainment, Ltd., No. 97-56418 (9th Cir., July 16, 1999) upholds a district court grant of summary judgment in a case claiming breach of an alleged exclusive license to broadcast certain programs. The Ninth Circuit agrees that fax documents and internal memoranda do not satisfy the writing requirement of sec. 204(a).

I had thought it was clear that 204(a) applied to copyright transfers and assignments but not to license agreements. Am I wrong, or is the Ninth Circuit a bottle short of a six-pack.

John Noble
<jnoble[_at_]dgsys.com> Received on Fri Aug 27 1999 - 21:20:15 GMT